2019 Annual Report (^69)
and oversee trade compliance in each link of our
business operations, ranging from procurement, R&D,
and sales, to supply and services.
Huawei continuously works to increase employee
awareness of trade compliance, and requires them to
sign the BCGs each year, which includes commitments
to observing applicable export control laws and
regulations. Huawei provides a wide variety of training
on trade compliance to managers and employees
across the company. These efforts, combined with
targeted training for specific business scenarios, allow
employees to fully understand the company’s and their
own responsibilities and obligations regarding export
control.
Ever since Huawei Technologies Co., Ltd. and some of
its affiliates were added to the Entity List by the US
Department of Commerce, the company has reiterated
the importance of compliance with export control and
work to ensure control measures are in place. We
have also promptly communicated with our customers,
suppliers, and other partners, enhancing mutual
understanding and trust.
Financial Compliance
Huawei earnestly fulfills legal obligations and social
responsibilities, and attaches great importance to
the management of financial compliance risks,
including but not limited to the risks of financial
sanctions, money laundering, and terrorist financing.
We invest ongoing efforts into building a culture
that is conducive to financial compliance and raising
employee awareness in this regard. We manage key
elements for financial compliance according to factors
such as country, customer, and transaction type,
incorporate key control points into our procurement,
sales, and treasury processes, and constantly improve
our IT systems, ensuring the financial compliance risks
of different business domains are effectively managed
before, during, and after the process.
Anti-Bribery Compliance
Huawei has a zero tolerance policy towards corruption
and bribery. We will continue to strengthen our
anti-bribery compliance system at the group and
subsidiary levels in four ways: a culture of compliance,
governance and oversight, compliance risk assessment
and prevention-discovery-response techniques, and
continuous operations. In addition, we have assigned
key roles for the group and business departments, who
are responsible for controlling anti-bribery risks and
providing support for operations of the anti-bribery
compliance system.
IPR and Trade Secret Protection
Respecting and protecting IPR: Huawei invests
long-term in R&D and continuously enriches its IPR
portfolio. Huawei is one of the world’s largest patent
holders, and the company believes that respecting
and protecting IPR is the foundation of innovation. As
a follower, practitioner, and contributor of IPR rules,
as well as an innovator, Huawei protects its own IPR
and respects the IPR of others. Huawei has reached
cross-licensing agreements with major ICT companies
around the world, and works tirelessly to improve the
environment for protecting innovation and IPR in the
industry and across countries and regions.
Respecting and protecting the trade secrets of
others: Huawei respects and protects trade secrets
of third parties, and complies with all applicable laws
and regulations relating to trade secret protection.
In addition, we have embedded requirements for
protecting trade secrets into our policies, systems,
and processes. We deliver training on trade secret
compliance to all employees, track relevant legislation
around the world, and proactively communicate with
judicial bodies and law firms. This has allowed us
to build a mature management system for ensuring
compliance with trade secret rules.
Regional Compliance Management
Huawei has appointed a compliance officer for
each of our subsidiaries worldwide and established
oversight-oriented subsidiary boards, which manage
and oversee the operational compliance of these
subsidiaries.
■ The company has incorporated compliance into key
performance indicators (KPIs) of its subsidiaries,
and established an award and disciplinary
mechanism to steer compliance management
among subsidiaries.
■ Under the guidance of the group’s unified
compliance requirements, all subsidiaries set their
own compliance management policies and systems
with reference to local laws and regulations, and
ensure appropriate compliance management in the
countries and regions where we operate.
coco
(coco)
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