ZTE Corporation Reaches Settlement with U.S. Authorities - Seite 2

Under Dr. Zhao's direction, ZTE remains focused on enhancing its procedures and controls and continuing to create a strong compliance culture throughout the organization.  During recent months, the company has invested in extensive reforms to create a leading export compliance program including the following actions:

• New CEO and Company Leadership. ZTE appointed Dr. Zhao as Chairman and Chief Executive Officer and made major changes to the senior management team, all of whom have a mandate of leading a new ZTE with a best-in-class export compliance program.
• New Compliance Committee. ZTE created a Chief Executive Officer-led Compliance Committee with the authority and remit to significantly change the company's policies and procedures, and provide greater oversight of support for the compliance initiatives.  
• Restructured Legal and Compliance Departments. ZTE removed compliance from the responsibility of the legal department and created a separate compliance department with increased headcount to build the compliance program with full independence.
• New U.S. Lawyer Named Chief Export Compliance Officer. A new Chief Export Compliance Officer, U.S. lawyer Matt Bell, was hired with responsibility for overseeing the continued development and improvement of the global export compliance program. Mr. Bell has experience developing and improving compliance programs for major multinational companies throughout his career.
• Expanded Export Control Compliance Manual. ZTE issued a new Export Control Compliance Manual created in conjunction with the review of BIS to provide more detailed guidance to the employees. ZTE also now requires an annual Compliance Commitment Agreement from all employees.  
• New Automated Tools and Processes. ZTE implemented a software automation tool which screens shipments from ZTE Corporation and certain subsidiaries for export control obligations. The system is used to determine which items are subject to the Export Administration Regulations (EAR), provides embargo and restricted party screening on the transactions, and places shipments on hold that require detailed classification analysis, application of license exceptions, or application of licenses when necessary. ZTE continues to make significant investments in automation to roll this out to its subsidiaries around the world.
• Global Export Controls Training. ZTE trained over 45,000 employees on export controls and sanctions laws and company policies in 2016. ZTE is continuing these general awareness trainings in 2017 while also rolling out more targeted training for critical functions such as sales, procurement, R&D and supply chain.

BIS will recommend that ZTE be removed from the Entity list, conditioned on court approval of the DOJ agreement, entry of the plea, and the issuance of BIS's settlement Order.