Statement of Compliance with Export Control Regulations
Hytera Communications Corporation Limited (Hereinafter referred to as “Hytera”) holds firmly the position that, observing strictly export control regulations of the Chinese government and other foreign government, related international organizations（including United States，European union）and fulfilling the export control obligations and responsibilities will enable Hytera to evade and mitigate trade risk, to build a corporate image as an honest and responsible enterprise to win trust from the international partners and customers, and it also contributes to increase our competitiveness in the international markets and lay a good foundation for Hytera’s sustainable development.
As a responsible global enterprise, Hytera is committed to observing export control regulations and fulfilling its obligations.Hytera affirms its unequivocal and emphatic support for the Chinese government’s nonproliferation and strategic trade control policies, which Hytera commits to abiding by fully and uncompromisingly. Hytera resolutely supports the Chinese government’s international commitments and obligations, the United Nations Security Council’s resolutions, and other countries and related international organizations’ best practices in the area of export control.
Hytera will establish and implement its internal export control rules with a view to full control, and place obligation of export control above our commercial profit.Hytera will make all efforts and take all measures to ensure any product, technology and service to be used for peaceful and reasonable. If Hytera believes that the products, technologies and services to be exported, whether physically or intangibly, might be used by our customers or end-users for developing or manufacturing weapons of mass destruction, delivery mechanisms, or unauthorized conventional military equipment that may jeopardize the national or regional peace or stability, or fall into the hands of terrorist organizations, Hytera will refuse to export related products, technologies, and services. In order to better comply with export control regulations and fulfill the relevant export control obligations, Hytera also will pushes any corporation entity, other organization or individual who agent or resell products, technologies and services to consult legal counsel and related government on local export control regulations. In addition, Hytera will make great efforts to check any third party involved the entire business process (such as the carrier, customs clearing agent and individual, etc.), once verified, Hytera will refrain from engaging in business with such corporation entities, organizations or individuals to prevent from potential proliferation diversion risk.
To ensure the effective implementation of its self-discipline mechanism, Hytera establishes export control verification and response team, which is authorized to veto any order in question, led by the legal supervisor. Hytera also establishes export control regulations, standard procedures for export auditing, archived related documents, launched promotion and training regarding export control rules and regulations, strengthened internal auditing, and clearly defined the responsibilities of the departments involved in export control. In the future, for the purpose of achieving informatization of Hytera’s export control mechanism, Hytera will establish databases for sensitive countries, sensitive end-users and sensitive products.
As an international enterprise, in order to fulfill the obligation of export control, Hytera acknowledges that we not only need to strengthen the construction of institutions and staff arrangement, formulate and implement strictly relevant internal control system, but also we must establish and maintain closer contact with related Chinese government departments, other countries and related international organizations, and experts, to obtain relevant technical information, expert guidance and advice.
The entire staff of Hytera must work toward meeting Hytera's export control targets and strictly carry out related corporate policies. Hytera has established a reward and punishment system to reward staff members who successfully follow Hytera 's export control policies, and to penalize strictly those who violate these policies. Employees who violate laws and regulations shall be legally accountable.
This statement is not intended to be a comprehensive summary of the export and import laws and regulations that govern Hytera’s products, technologies and services. You are responsible to consult with a legal counsel to ensure compliance with applicable laws and regulations. To keep in line with the latest laws and regulations of Chinese government, other countries and organizations as well as the applicable international commitments regarding export control of Chinese government, Hytera will review and revise the statement annually according to related laws and regulations.
This statement applies to all Hytera departments, subsidiaries, and branches. The statement incorporated herein has been or will be implemented within the framework of Hytera’s existing internal compliance program.