Safety Information

SUBJECT: Open Letter and Notice to Directors, Officers, Employees, Contractors, Suppliers,
and Business Partners Regarding Prohibited Transfers of Items Subject to the EAR to
Restricted Regions
ZTE Corporation and its subsidiaries and branches (collectively, “ZTE”) are fully committed to
compliance with all applicable export control and economic sanctions laws and regulations.
It is ZTE policy to fully comply with all local rules and regulations. This includes compliance
with the economic sanctions and export control laws and regulations of the countries in which
it operates and conducts business. Compliance with these laws and with ZTE’s Export
Compliance Program are essential requirements for ZTE's employees, contractors, and
businesses.
ZTE hereby informs its leadership, management, employees, contractors, suppliers, and
others who deal in items subject to the U.S. Export Administration Regulations (“EAR”) that
transfers of such items to Iran, North Korea, Syria, Cuba, and Crimea, are generally prohibited.
This prohibition applies to all U.S.-origin items and non-U.S.-origin items containing more
than the applicable de minimis content by value (as set forth in the EAR). The only
exceptions to this prohibition are transfers that are authorized (1) by the EAR, (2) by the
regulations administered by the U.S. Department of the Treasury’s Office of Foreign Assets
Control (“OFAC”), and (3) by the U.S. Government through the issuance of a license.
It is current ZTE policy to not conduct business with any parties located, headquartered,
registered, or operating in countries or regions that are sanctioned by the United States
(currently Iran, Sudan, Syria, North Korea, Cuba, and Crimea). It is ZTE policy to not do
business directly or indirectly related to these countries or regions even if the transaction does
not involve items subject to the EAR.
A violation of the export control and economic sanctions laws and regulations may result in
serious legal consequences for a company or other entities and responsible individuals.
These consequences include (but are not limited to) fines, trade restrictions, criminal
prosecution, and imprisonment. ZTE is committed to abiding by all applicable export control
and economic sanctions laws and regulations worldwide, and ZTE will implement measures
to ensure compliance with all legal requirements relating to exports, re-exports and transfers
(in-country) of hardware, software and technology.
ZTE expects and calls for our directors, officers, employees, customers, suppliers and other
business partners to:
1. Fully understand and strictly comply with all applicable domestic and international export
control law and economic sanctions laws and regulations.
2. For all hardware, software and technology provided to ZTE, provide the applicable export
control classification information and supporting documents to ZTE during sales, supply and
licensing. This includes informing ZTE whether the items being provided to ZTE are subject to