Hytera Communications Corporation Limited (Hereinafter referred to as “Hytera”) holds firmly the position that, observing strictly applicable export control regulations of China and other countries, relevant 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 corporate image as an honest and responsible enterprise to win trust from 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.
Hytera 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 of its product, technology and service be used for peaceful and reasonable motivations. 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 directly or indirectly 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 in the entire business process (such as the carrier, customs clearing agent and individual, etc.), once verified illegal, Hytera will refrain from engaging in business with such corporation entities, organizations or individuals to prevent from potential risk.
To ensure the effective implementation of the internal export control compliance program, Hytera established Trade Compliance and Import &Export Control Committee, hosted by senior management in charge of trade compliance and import & export control. Hytera also establishes export control rules, standard procedures for export auditing, archived related documents, launched promotion and training regarding export control laws and regulations, strengthened internal auditing, and clearly defined the responsibilities of the departments involved in export control.
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 compliance 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 compliance policies, and to penalize strictly those who violate these policies. Employees who violate laws and regulations will be subject to severely disciplinary actions by relevant department of the Company.
This statement is not intended to be a comprehensive summary of the export control compliance rules and policies 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 China and other countries，relevant organizations as well as the applicable international commitments by Chinese government, Hytera will review and revise the statement periodically according to related laws and regulations.
This statement applies to all Hytera departments, subsidiaries, and branches. The statement incorporated is implemented within the framework of Hytera’s existing internal compliance program.
Hytera Communications Corporation Limited
May 2, 2018