Compliance management
CICT Mobile Communication Technology Co., Ltd. and its majority owned or controlled subsidiaries and affiliates (collectively, "CICT Mobile") are fully committed to compliance with all applicable export control and economic sanctions laws and regulations in China and other countries, including those of the United States. CICT Mobile has committed and will continue to commit substantial resources to ensure compliance with applicable export control and economic sanctions laws and regulations around the world. CICT Mobile firmly believes that conscientiously adhering to Chinese and international export control laws and regulations, including those of the United States, can effectively mitigate and reduce transaction risks, continually enhance CICT Mobile's market competitiveness, and provide effective guarantees for its long-term development.
CICT Mobile hereby promises to comply with all relevant export control laws and regulations related to the company's operations, as promulgated by the Chinese government and international export management laws and regulations, including those of the United States. CICT Mobile supports China's government international commitments, including the international obligations assumed by the Chinese government to implement relevant resolutions of the United Nations Security Council. At the same time, CICT Mobile adopts a responsible attitude and measures in the field of export control, seriously considering compliance requirements related to CICT Mobile's operations and fulfilling its responsibilities.
CICT Mobile adopts the principle of comprehensive control to guide the establishment and implementation of the company's internal export control mechanisms, prioritizing its export control obligations above its commercial interests.
If CICT Mobile believes that tangible or intangible products, technologies, and services to be exported may be used by customers or end-users for the development or production of weapons of mass destruction and their delivery systems or unauthorized conventional military equipment, which are detrimental to the peace and stability of recipient countries or regions, or may fall into the hands of terrorist organizations, CICT Mobile will voluntarily implement strict export control measures based on the principle of comprehensive control and refuse to export the related products, technologies, and services. Adhering to the principle of "deemed exports" control, CICT Mobile will also carry out internal monitoring and regulation to prevent employees from coming into contact with individuals or organizations that may maliciously use sensitive technology or information.
CICT Mobile also verifies intermediaries that may be used in its business operations to avoid potential risks of proliferation, transfer, and violations of economic sanctions. CICT Mobile refuses to conduct business with illegal companies or individuals. CICT Mobile realizes that in implementing actual measures to confirm sensitive customers, differentiate product codes according to international and national standards, and determine the ultimate use of products, further establishing and maintaining close contacts with relevant government departments, relevant non-governmental organizations, and export control experts in China is necessary to obtain relevant technical information, seek professional guidance, and authoritative advice.
To ensure the effective implementation of the company's self-discipline mechanisms, CICT Mobile has established the position of Chief Compliance Officer and established a Compliance Management Leadership Group and a Compliance Management Working Group, led by the company's general manager and composed of senior management personnel, to comprehensively organize, coordinate, and guide the company's compliance management work and review, supervise, and inspect the compliance of the company's departments' business operations and business conduct. The Legal and Intellectual Property Department is responsible for implementing specific tasks assigned by the Compliance Management Working Group. The Compliance Management Working Group has the authority to veto transactions with identified issues.
In terms of corporate systems, CICT Mobile has developed export control management systems, conducts promotion and training on export control regulations and systems, strengthens internal audits, and implements the responsibilities of each department involved in export control.
All employees of CICT Mobile must make efforts to achieve the company's export control objectives and strictly comply with the company's relevant policies. The company has established a reward and punishment system to reward employees who actively participate in export control work and to notify and impose severe penalties on employees who violate the company's export control policies. Employees who violate national laws and regulations will be held legally accountable.
This statement applies to all departments, subsidiaries, and branches of CICT Mobile Communication Technology Co., Ltd.
To comply with the latest regulations of the Chinese government and other countries, including the United States, regarding export control, and corresponding international commitments, the company will conduct an annual review of this statement and revise it in accordance with relevant legal requirements.
CICT Mobile hereby promises to comply with all relevant export control laws and regulations related to the company's operations, as promulgated by the Chinese government and international export management laws and regulations, including those of the United States. CICT Mobile supports China's government international commitments, including the international obligations assumed by the Chinese government to implement relevant resolutions of the United Nations Security Council. At the same time, CICT Mobile adopts a responsible attitude and measures in the field of export control, seriously considering compliance requirements related to CICT Mobile's operations and fulfilling its responsibilities.
CICT Mobile adopts the principle of comprehensive control to guide the establishment and implementation of the company's internal export control mechanisms, prioritizing its export control obligations above its commercial interests.
If CICT Mobile believes that tangible or intangible products, technologies, and services to be exported may be used by customers or end-users for the development or production of weapons of mass destruction and their delivery systems or unauthorized conventional military equipment, which are detrimental to the peace and stability of recipient countries or regions, or may fall into the hands of terrorist organizations, CICT Mobile will voluntarily implement strict export control measures based on the principle of comprehensive control and refuse to export the related products, technologies, and services. Adhering to the principle of "deemed exports" control, CICT Mobile will also carry out internal monitoring and regulation to prevent employees from coming into contact with individuals or organizations that may maliciously use sensitive technology or information.
CICT Mobile also verifies intermediaries that may be used in its business operations to avoid potential risks of proliferation, transfer, and violations of economic sanctions. CICT Mobile refuses to conduct business with illegal companies or individuals. CICT Mobile realizes that in implementing actual measures to confirm sensitive customers, differentiate product codes according to international and national standards, and determine the ultimate use of products, further establishing and maintaining close contacts with relevant government departments, relevant non-governmental organizations, and export control experts in China is necessary to obtain relevant technical information, seek professional guidance, and authoritative advice.
To ensure the effective implementation of the company's self-discipline mechanisms, CICT Mobile has established the position of Chief Compliance Officer and established a Compliance Management Leadership Group and a Compliance Management Working Group, led by the company's general manager and composed of senior management personnel, to comprehensively organize, coordinate, and guide the company's compliance management work and review, supervise, and inspect the compliance of the company's departments' business operations and business conduct. The Legal and Intellectual Property Department is responsible for implementing specific tasks assigned by the Compliance Management Working Group. The Compliance Management Working Group has the authority to veto transactions with identified issues.
In terms of corporate systems, CICT Mobile has developed export control management systems, conducts promotion and training on export control regulations and systems, strengthens internal audits, and implements the responsibilities of each department involved in export control.
All employees of CICT Mobile must make efforts to achieve the company's export control objectives and strictly comply with the company's relevant policies. The company has established a reward and punishment system to reward employees who actively participate in export control work and to notify and impose severe penalties on employees who violate the company's export control policies. Employees who violate national laws and regulations will be held legally accountable.
This statement applies to all departments, subsidiaries, and branches of CICT Mobile Communication Technology Co., Ltd.
To comply with the latest regulations of the Chinese government and other countries, including the United States, regarding export control, and corresponding international commitments, the company will conduct an annual review of this statement and revise it in accordance with relevant legal requirements.