Yin Yimins internal letter explains the whole process of being sanctioned by the United States: determined to safeguard its interests through legal means.

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 Yin Yimins internal letter explains the whole process of being sanctioned by the United States: determined to safeguard its interests through legal means.


Yin Yimin once again stressed that BISs insistence on the most severe sanctions against ZTE is extremely unfair and unacceptable. The company will not give up efforts to solve problems through communication and dialogue, and is determined to safeguard its legitimate rights and interests through all the means permitted by law. Yin Yimin said. (quiet) All the colleagues of the company: In April 16, 2018, it was four days and nights in which the US Department of Commerce was informed of the refusal of the company to activate the company. The events have aroused the high attention of all employees, family members and all walks of life. For the first time, the company set up a crisis response team to comprehensively assess the impact of the event on the company and its employees, and to maintain a positive communication with the parties to promote the solution of the event with the greatest effort. During this period, all the staff of the company are united, stick to their jobs, do their job well, and tide over the difficulties with the company through practical actions. Thank you! We are faced with complex international situations, opportunities and challenges. Over the past year or more, we have adhered to compliance as one of the cornerstones of our companys strategy, and adhered to the principle of export control compliance is the most important principle. The company complies with the U. S. export control law and conscientiously fulfil the relevant agreement obligations signed by the US government in March 2017. The company pays a fine of over $800 million on schedule. In 2017 alone, the company invested more than $50 million for export control compliance, and plans to invest more resources in 2018. The company supports the independent ombudsman appointed by the US side (hereinafter referred to as the inspector) to carry out various supervision work including interviews, document submissions and system testing, with a cumulative output of more than 132 thousand pages. The company is committed to building a first-class, standardized and sustainable compliance management system from the management to the staff, the whole staff participation, and the whole effort. Through continuous efforts and advancement, we have established professional compliance teams to build and optimize the regulatory framework, system and process of the companys import and export control, the introduction and implementation of the SAP trade compliance management tool (GTS), the promotion of IT automation control, and general compliance training and more than 65000 employees worldwide. 45000 employees have made great progress in compliance culture and system construction through compliance training at specific key positions. In the process of promoting compliance construction, we learned from past lessons and corrected them in time, and never made any mistakes made by some management cadres in the past. The whole event is as follows: In November 30, 2016, the company submitted a letter to the relevant departments of the US government. (1) to take disciplinary measures (disciplinary measures including job adjustment, bonus deductions, and send disciplinary letters) on some executives and employees involved in the trading of the country. Some of these measures have been implemented and the other part has been implemented as planned. (2) progress report on ZTEs construction of export control compliance system and future plans. In March 2017, the company reached agreement with the Department of industry and safety of the United States Department of Commerce (hereinafter referred to as BIS), the United States Department of Justice (hereinafter referred to as DOJ), the U. S. Treasury Departments overseas asset management office (hereinafter referred to as the relevant agreement). The company and the DOJ agreement require 4 Executives / employees to leave the company. Except for the 4 parties, there are no other disciplinary requirements in the relevant agreements. In May 9, 2017, the company informed the US government about the status of 4 Executives / employees who had left the company and the supporting documents. In July 20, 2017, the first law firm hired by the company sent a letter to the United States government to describe the completion of disciplinary measures for some employees. At the end of February 2018, at the end of February 2018, the companys chief export control compliance officer and the companys second outside law firms gathered information in succession, showing that the companys bonus reduction plan for some employees was not in time. On the morning of March 5, 2018, the companys chief export control compliance officer and the companys second outside law firms reported to me about the matter and suggested a series of actions, and I agreed and arranged for a quick action. On the afternoon of the same day, President Zhao Xianming affirmed his support for these actions and stressed that such actions should be transparent and realistic. The company quickly arranged second law firms to carry out a survey on the situation (hereinafter referred to as investigation), and the company conducted internal verification of the performance of disciplinary measures for employees. On the morning of March 7, 2018 (March 6th of the US time), the company took the initiative to report relevant information to relevant departments and monitors of the US government. In March 8, 2018, the company issued disciplinary letters to its incumbent employees and made arrangements for the deduction of 2016 bonus, which will be deducted from the bonus of 2017. In March 14, 2018, the sending of disciplinary letters to the departing employees will be carried out in the case of Chinese law. In March 8, 2018, the company took the initiative to report the relevant situation to the North District Court of Texas. Since then, under the advice of the chief export control compliance officer and second law firms, the company hired another law firm to carry out parallel investigations in March 12, 2018. The investigation was still in progress until April 15, 2018 when BIS activated the refusal order. Prior to the completion of the independent investigation, the Department of Commerce of the United States alleged that the company had false statements in the letter of November 30, 2016 and in the correspondence of July 20, 2017, and then made a punishment for the activation of the refusal order. BIS ignored the hard efforts, great investment and great progress of the company in the past two years to comply with the compliance of export control. The problem of ignoring the above two letters is a timely notification by the companys self investigation and discovery, ignoring the companys first time to deal with negligent responsible persons, quickly correcting the problem and hiring authoritative American lawyer affairs. Investigation. Before the end of the relevant investigation, BIS insisted on giving the company the most severe sanctions, which is extremely unfair to the company. We can not accept it. The company will not give up its efforts to solve problems through communication and dialogue, and is determined to safeguard its legitimate rights and interests through all the means permitted by law. The companys board of directors, management and staff will unite and fulfill their duties and never give up. Although the company is in a very difficult situation, at the first time after the refusal order is completed, the compliance team has reached the code of conduct for all the employees in the case of activating the refusal order, reflecting the firms adherence to the laws and regulations of the country of the business and the determination to be the cornerstone of the companys strategy. . The board of directors and management will do the best to protect the legal rights of the eighty thousand employees, as well as the legitimate interests of the eighty thousand employees families, and will make the best efforts to fulfill our responsibility for the hundreds of operators, thousands of partners and suppliers in the world, and the end-end consumer users of hundreds of millions of companies. Ren will also do his best to protect the interests of the about three hundred thousand shareholders of the world. At the same time, I appeal to all employees of the company to view this incident rationally and objectively and avoid overemotional. The company promises that the final findings will be disclosed to all staff with the consent of the lawyer. Adhering to an open, transparent and honest attitude, the company will continue to communicate and solve problems in a lawful and compliance way, and do its best to reduce the adverse impact of this matter. Let us strengthen our belief and unite as one.