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Huawei Supplier Social Responsibility Code of Conduct

Huawei is a leading global provider of information and communications technology (ICT) infrastructure and smart devices. Our mission is to bring digital to every person, home and organization for a fully connected, intelligent world. To this end, Huawei is committed to supporting the United Nations Sustainable Development Goals (SDGs) and working closely with our partners up and down the supply chain to fulfil our corporate social responsibility (CSR) and create a sustainable value chain.

This Huawei Supplier Social Responsibility Code of Conduct (hereinafter referred to as the "Code") has been developed with reference to the Responsible Business Alliance (RBA) Code of Conduct and Joint Audit Cooperation (JAC) Supply Chain Sustainability Guidelines as a part of Huawei's supplier CSR agreement and CSR requirements to all suppliers.

Huawei requires suppliers to comply with all the applicable laws and regulations as a prerequisite for cooperation with Huawei. We encourage suppliers to draw on internationally recognized industry standards and best practices to improve their CSR management. With reasonable notice, Huawei has the right to carry out onsite audits of suppliers to assess their compliance with this Code.

Huawei adopts the Organization for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Business Conduct to develop an effective procurement CSR management system. Huawei incorporates CSR into every phase of our procurement process, from materials qualification and supplier qualification and selection to performance evaluation and portfolio management. When suppliers are equally matched in other factors, those that perform better in CSR are given priority in terms of the share of business or business opportunities. For those suppliers with poor CSR performance, especially those which have violated CSR redlines, Huawei will require them to resolve existing issues within an agreed timeframe, reduce their share of business, offer them fewer business opportunities, or in the worst case, end our partnership.

This Code applies to all suppliers who provide products and/or services to Huawei Investment & Holding Co., Ltd. or its global subsidiaries and affiliates (hereinafter referred to as "Huawei"). This Code applies to all workers, including temporary workers, migrant workers, apprentices, student workers, contract workers, direct employees, and any other type of workers.

This Code consists of five sections: Labor, Health and Safety, Environment, Business Ethics, and Management Systems.

1. Labor Standards

1.1 Prohibition of Forced Labor

Suppliers must ensure that all workers are employed on a purely voluntary basis. Forced labor in any form is not permitted. Suppliers must not employ any form of slave labor (including modern slavery), forced labor, bonded labor, indentured labor, or prison labor. Suppliers must not restrict workers' freedom of movement, retain workers' identity documents, or engage in any form of human trafficking. This includes transporting, harboring, recruiting, transferring or receiving persons by means of threat, force, coercion, abduction or fraud for labor or services. Workers shall not be required to pay any deposit, recruitment fee, or any other fee to their employer or an agent.

1.2 Child Labor and Young Workers

1. Suppliers must comply with all applicable laws in their country relating to minimum working age, and must not use child labor in any form.

2. Suppliers shall implement an appropriate mechanism to verify the age of workers. Workers under the age of 18 shall not perform work that is likely to jeopardize their health or safety.

3. Suppliers shall ensure proper protections for student workers and apprentices in accordance with applicable law and regulations.

1.3 Working Hours

Suppliers shall comply with all applicable laws and regulations relating to working hours and breaks. All overtime must be voluntary. The standard working week (excluding overtime) should be defined based on local law, but should not exceed 48 hours; total working hours in any week should not exceed 60 hours. Workers should at least have one day off after every six consecutive days of work.

1.4 Wages and Benefits

Compensation paid to workers shall comply with all applicable wage laws, including those relating to minimum wages, overtime hours and legally mandated benefits. Workers should receive their wages directly, in full and on time, and must be provided with an understandable wage statement. Deductions from wages as a disciplinary measure shall not be permitted.

1.5 Humane Treatment

Suppliers must not use violence, verbal abuse, threats, corporal punishment, sexual abuse, or physical coercion against workers; nor is there to be the threat of any such treatment.

1.6 Non-discrimination

Suppliers must not engage in discrimination based on race, color, age, gender, sexual orientation, gender identity or expression, ethnicity or national origin, disability, pregnancy, religion, political affiliation, membership of an organization, protected genetic information or marital status in hiring and employment practices such as wages, promotions, rewards, access to training, and termination. In addition, workers or potential workers should not be subjected to medical tests or physical exams that could be used in a discriminatory way.

1.7 Freedom of Association and Collective Bargaining

In conformance with local law, suppliers shall respect the right of all workers to form and join trade unions of their own choosing, to bargain collectively and to engage in peaceful assembly as well as respect the right of workers to refrain from such activities. Suppliers should establish channels for communication between the company and its workers or their representatives, and should hold regular engagement sessions. Workers and/or their representatives shall be able to openly communicate and share ideas and concerns with management regarding working conditions and management practices without fear of discrimination, reprisal, intimidation or harassment.

2.Health and Safety

Suppliers must provide a healthy and safe working environment, which shall be maintained through ongoing, systematic monitoring of workers' health and working environments. They must ensure that workers do not have to work in conditions which seriously threaten their health or safety. Risks of fire and explosion must be controlled, and steps must be taken to prevent any fatalities in industrial accidents, and potential incidents and occupational illness arising out of, associated with or occurring in the course of work such as epidemics.

2.1 Working Conditions

1. Suppliers must obtain, maintain, and keep up to date all the required health and safety certificates, and must comply with the requirements of those certificates.

2. Suppliers should identify potential safety hazards (fire safety, electrical and other energy sources, industrial hygiene, physically demanding work, machine safeguarding, vehicles, and fall hazards, etc.) and control them through proper design, replacement of dangerous equipment, engineering controls, preventative maintenance and safe working procedures (including lockout/tagout). Where necessary, workers are to be provided with proper personal protective equipment. Supplier should take reasonable action to protect female workers, especially for pregnant women and nursing mothers.

3. Procedures and systems are to be in place to prevent, manage, track and report occupational injury and illness including provisions to implement corrective actions to eliminate their causes and facilitate return of workers to work. Suppliers shall allow workers to remove themselves from imminent harm, and not return until the situation is mitigated, without fear of retaliation.

4. Suppliers shall provide workers with appropriate health and safety training in local language. Health and safety related information shall be clearly posted in the facility or placed in a location identifiable and accessible by workers. Health information and training shall include content on specific risks to relevant demographics, such as gender and age, if applicable.

2.2 Living Conditions

Workers should be provided with ready access to clean toilet facilities, potable water and sanitary food preparation, storage and eating facilities. Workers dormitories should be clean and safe and have adequate personal space.

2.3 Emergency Preparedness

Potential emergency situations and events are to be identified and assessed, including, but not limited to, risk of fire, explosion, fatal accidents, and mass poisoning. Suppliers shall create and implement emergency plans and response procedures including emergency reporting, emergency treatment, employee notification and evacuation procedures, worker training and drills, and recovery plans. Such plans and procedures shall focus on minimizing harm to life, the environment, and property.

2.4 Absolute Rules

Suppliers shall observe the following safety rules, and ensure that all workers are aware and comply and monitor their compliance:

1. Working at height:

(1) Never work at height without appropriate training and qualifications

(2) Always use suitable personal protective equipment

(3) Never walk or stand underneath hoisting equipment

(4) Never drop tools or other objects when working at height

2. Driving:

(1) Always wear seat belts when traveling in or operating vehicles

(2) Never use a hand-held phone whilst driving

(3) Never exceed speed limits

(4) Never drive when fatigued

3. Electrical work:

Never work on electrical equipment without proper training and qualifications.

4. Alcohol and drugs:

Never work under the influence of alcohol or other drugs.

3.Environmental Protection

3.1 Environmental Permits and Reporting

Suppliers shall obtain, maintain and keep current all necessary environmental permits (e.g., discharge monitoring), approvals and registrations and shall comply with their operational and reporting requirements.

3.2 Product Environmental Requirements

Suppliers shall respect all applicable laws, regulations and customer requirements regarding prohibition or restriction of specific substances such as RoHS and REACH, and take effective measures to prohibit or restrict the use of specific substances in products and manufacturing.

3.3 Pollution Prevention

Suppliers shall respect all applicable environmental laws and regulations on pollutants (i.e., wastewater, exhaust gases, and solid waste), including rules on their creation, transport, storage, disposal and release into the environment, and minimize or eliminate emissions and discharges of pollutants and generation of waste at the source. No harmful pollutants may be released into the environment, including but not limited to waste water, gases, slurry and noise.

3.4 Hazardous Substances

Chemicals, waste, and other materials posing a hazard to humans or the environment shall be identified, labeled, and managed to ensure their safe handling, movement, storage, use, recycling or reuse, and disposal. Hazardous waste data shall be tracked and documented.

3.5 Energy Consumption and Greenhouse Gas Emission

Suppliers shall establish an absolute corporate-wide greenhouse gas reduction goal. Energy consumption and greenhouse gas emissions shall be tracked and documented. Suppliers should take steps to cut their use of resources and find low-impact substitutes, reduce their consumption of energy, water, and natural resources, and look for methods to improve energy efficiency and to minimize their energy consumption and greenhouse gas emissions.

4.Business Ethics

4.1 Integrity

Suppliers may not engage in bribery or unethical conduct. Suppliers must follow the requirements of "no bribery, no gifts, no conflicts of interest, no falsification, no cutting corners, no fraud, and keeping promises".

4.2 Intellectual Property

Intellectual property rights are to be respected; transfer of technology and know-how is to be done in a manner that protects intellectual property rights and customer information is to be safeguarded.

4.3 Fair Business, Advertising and Competition

Standards of fair business, advertising and competition are to be upheld.

4.4 Protection of Identity and Non-Retaliation

Programs that ensure the confidentiality, anonymity and protection of supplier and employee whistleblowers are to be maintained, unless prohibited by law. Supplier should have a communicated process for their personnel to be able to raise any concerns without fear of retaliation.

4.5 Responsible Sourcing of Minerals

Suppliers shall take reasonable action and exercise due diligence on the source and chain of custody of the tantalum, tin, tungsten, gold, and cobalt in the products they manufacture to reasonably assure that they are sourced in a way consistent with the OECD Guidance for Responsible Supply Chains of Minerals from Conflict- Affected and High-Risk Areas or an equivalent and recognized due diligence framework. Suppliers shall provide these due diligence information to customers upon request.

4.6 Privacy

Supplier shall commit to protecting the reasonable privacy expectations of personal information of everyone they do business with, including suppliers, customers, consumers and employees. Supplier shall comply with privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted, and shared.

5.Management Systems

5.1 Company Commitment and Management Accountability and Responsibility

Supplier top management shall endorse the CSR policy statement in local language affirming their commitment to compliance with all applicable laws, industry standards, customer requirements and this Code and continuous improvement.

Suppliers should assign a senior executive for CSR and establish accountability mechanisms based on the principle that CSR management is part of business management. Suppliers shall integrate CSR into corporate operations and arrange customer onsite audits and information disclosure upon request.

5.2 Risk Assessment and Risk Management

Suppliers shall identify CSR risks and opportunities related to their own operations on the basis of applicable laws, industry standards, customer requirements, this Code and their own strategic needs. They shall implement appropriate actions to control and mitigate the identified risks.

5.3 Management of Upstream Suppliers

Suppliers should establish a procurement CSR management system and incorporate this Code into the procurement process for their upstream suppliers, including written commitment, criteria of qualification, selection, due diligence and audit.

5.4 Internal Audit and Management Review

Senior management shall regularly assess the CSR performance of their own operations and their supply chain to ensure the suitability, adequacy and effectiveness of the CSR management system.

Huawei reserves the right to interpret this Code.