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Question 1

From the perspective of the four elements of Export Control Compliance, which Export Control Compliance risks do you think exist in the engineering service business?

Answer 1

Whether each element can be stated. (Product, Country, Party, End user)

Question 2

What are the Export Control Compliance risks in the customer support scenario?

Answer 2

Customers may come from sanctioned countries or regions, or restricted parties.

Question 3

Is there any regular technical preventive maintenance? What are the compliance requirements for preventive maintenance?

Answer 3

The CSC system creates a preventive maintenance application form.

Question 4

What are other KCP（Key Control Point） of the customer supports ?

Answer 4

Software application
Task execution
Creation of Preventive maintenance tasks
User login

Question 5

Have you ever upgraded software? What are the compliance requirements for this scenario?

Answer 5

CSC System

Question 6

How to conduct party screening on individuals when the LCM system is used?

Answer 6

Enter Pinyin for scanning. The surname and name are separated by spaces, and no punctuation mark is allowed.

Question 7

How to conduct party screening on enterprises when the LCM system is used?

Answer 7

Obtain the full official English name and scan it together. If there is no official English name, enter the full Chinese name and country information for scanning.

Question 8

Which systems or websites of ZTE can be used to query the ECCN information of materials?

Answer 8

ECCN system

Question 9

Which body publishes the Entity List in the United States?

Answer 9

Bis (Commercial Affairs Dept.)

Question 10

Where can I obtain the “Compliance Guidelines on Entity List Scenarios”?

Answer 10

LCM website

Question 11

How many years should Export Control Compliance related records be saved?(Such as party screening records and training records)

Answer 11

5 Years

Question 12

Which government agency appointed SCC in the United States?

Answer 12

Commercial Affairs Dept. (BIS)

Question 13

What is the SCC’s monitoring period for ZTE?

Answer 13

10 Years

Question 14

Where can I obtain the compliance manual released by the company in 2020?

Answer 14

PAL/iCenter

Question 15

Have you studied the Corporate-Level Manual and engineering service manuals? What are the differences between the Corporate-Level Manual and the Manual-Level Manual?

Answer 15

The Corporate-Level Manual describes basic requirements and ZTE’s compliance policies, and describes compliance risks and compliance control requirements in each business scenario.

Question 16

What are the Export Control Compliance red-line clauses released by the company?

Answer 16

Sanctioned countries/regions, restricted parties, military purposes, violations of human rights, or illegal listening/surveillance

Question 17

What is the internal reporting method for the compliance whistleblowing channels released by the company?

Answer 17

Mailbox complianceaudit@zte.com.cn

Question 18

What are the external independent third-party whistleblowing methods regarding the compliance whistleblowing channels released by the company?

Answer 18

Website, Email, and Telephone

Question 19

Which export control system must be automatically scanned for normal delivery from ZTE? Which of EAR elements will be scanned?

Answer 19

Country, subject, and product

Question 20

What are the sanctioned countries/regions in the U.S. Export Control Regulations EAR?

Answer 20

Iran, Syria, North Korea, Cuba, and the Crimea region

Question 21

According to the de minimis calculation requirements in the GTS system, for products exported to non-embargoed countries, how many U.S.-origin items do the U.S.-origin controlled components account for?

Answer 21

25%