Business Code of Conduct
Objectives
This Business Code of Conduct outlines the approach of Huawei Technologies Sweden AB (hereinafter referred to as “Huawei”) to the employee’s code in relation to business, together with an action plan which details how Huawei will achieve a professional and ethical working environment, which is inclusive and maximizes the potential of all staff and clients.
Scope
This Business Code of Conduct applies to:
1) all employees of Huawei; and
2) consultants, contractors, agency staff, intern and anyone retained to act on behalf of Huawei.
Statement of Trust
Huawei ethos since its early years can be summarized in one word – “Trust”, a core value which Huawei advocates at all times.
Huawei promises to be honest and trustworthy to customers and its staff in all aspects of its business interests and to encourage the promotion of harmony as part of the Company’s growth and development. The Company believes that trust as the core value, whilst being invisible, is an asset which makes up Huawei competitive edge and trust culture will result in long-lasting efforts by all employees and continued commitment from its customers.
Basic Conduct Guidelines
It is essential that employees should be seen to keep their promises, work in a professional and ethical manner.
● Comply with all applicable laws and regulations in each of the countries in which Huawei’s business operations,
including any laws, standards and principles relating to anti-bribery;
● Be honest, diligent and trustworthy in the treatment of all Huawei business activities and relationships;
● Protect and use Huawei assets in an appropriate manner and respect others’ intellectual property rights;
● Uphold Huawei interests and ensure that personal interests do not take priority over the interests of the Company;
Guidelines for Ethical Behavior
Business Activities and Relationships
Huawei employees shall conduct their business in a lawful and ethical manner at all times while conducting business activities and dealing with business relationships.
Anti-bribery and Corruption
Huawei recognizes that corruption can have a detrimental effect on society by undermining legal systems; damaging
social and economic development; and free and fair competition. Huawei is committed to carrying out our business
in an honest and ethical manner which is reflected within our business principles that form the foundation of
our Company.
Huawei has a zero tolerance of bribery and corruption. Huawei will comply in all respects with all applicable
domestic and international laws, standards and principles relating to anti-bribery in each of the countries in
which Huawei trades, operates or has any other activity.
We are committed to the following:-
● To carry out our business fairly, honestly and transparently;
● To not make or receive bribes, or condone the offering of bribes on our behalf, so as to gain or retain a
business advantage;
● Avoid doing business with others who do not accept our principles and who may harm our reputation;
● Keep transparent and updated records;
● Make sure that everyone in our business knows and adheres to our principles; and
Employees are referred to Huawei’s Anti-bribery and Corruption Policy for further guidance. Any Huawei employee who is found to be giving or taking bribes or any other acts of corruption, will be subject to disciplinary action..
Gifts and hospitality
Huawei employees must not solicit gifts or hospitality in any circumstances from any business partner. Notwithstanding this, Huawei recognizes that the occasional acceptance or offer of modest gifts and hospitality may be a legitimate contribution to good business relationships. However, it is important that gifts or hospitality shall be suitable for the conduct of normal business relationships and shall never influence business decision-making processes, or cause others to perceive as an influence. The prohibitions against accepting or paying bribes and the avoidance of conflicts of interest should always be taken into consideration.
You shall make sure you get the right approvals before you either offer or accept gifts or hospitality and register any gifts or hospitality that are offered to or accepted by you.
You may never accept or offer the following with or without approval:
● Illegal gifts or hospitality;
● Gifts or hospitality that is of an inappropriate nature or in inappropriate venues or that might adversely
affect Huawei’s reputation;
● Gifts or hospitality that the giver knows are prohibited by the recipient’s organization;
● Cash or cash equivalents such as gift vouchers, stocks, loans or options;
● Travel arrangement for the purpose of tourism, flight upgrading;
● Job arrangement for a relative of a customer (except where the job offer is made via a fair, public and formal
recruitment and selection procedure);
● Personal services;
● Gifts or hospitality during a tender exercise or during periods when important business decisions are being
made.
Employees are referred to Huawei’s Gifts and Hospitality Policy for detailed guidance on the acceptance and offering of gifts and hospitality. It is the responsibility of each Huawei employee to familiarize with the Gifts and Hospitality Policy and processes and to act accordingly. Huawei requires employees to abide by these rules not only to protect our reputation, but also to protect themselves against unfounded allegations of improper behavior.
Promotion and Commitment
Employees who are involved with Advertising and Marketing should make sure that promotional literature is accurate and truthful in regards to the promotion of the Company’s product and services.
The Selection of Suppliers
Huawei requires its employees to establish professional and legal relationships with all its suppliers, including business partners such as agents, distributors, joint ventures or allies. Meanwhile, Huawei will require its business partners to accept and honor the Huawei Code of Business Conduct.
Selection of suppliers will be based on objective business criterion and where an employee does not have the expert knowledge of the professional area of the supplier, they must seek an advice from an employee who does.
Ensuring Fair Transactions
Employees must not entrust business to a supplier owned or managed by his/her relative or close friend. If an employee’s relative has interests in one of Huawei suppliers, the Company will not enter into any form of business partnership with the supplier.
Business information of suppliers and other business partners must be kept confidential. Product conditions and quotations as well as Huawei assessment of suppliers are all trade secrets. No trade secret shall be disclosed to any other supplier.
Respecting Differences
Cultural differences and religious beliefs among customers, suppliers, business partners and the employees from all over the world must be respected at all times.
Complying with Local Country Laws and International Rules and Regulations
Huawei business reaches many countries worldwide and its employees have many different nationalities and ethnic beliefs. As a global operator we must ensure that our business operations are in compliance with the laws of local countries, regions, or regional economic communities, international practice and recognised standards. These laws or standards deal with a wide range of aspects, including investment, trade, foreign exchange, labor, environment, contract, consumer protection, bribery and corruption, intellectual property right, accounting and taxation.
● Employees will ensure that they understand and observe the laws and regulations relating to trade secret, proprietary information and other intellectual property rights, and respect others’ effective intellectual property rights. Avoid improper economic or criminal practices relating to the use of others’ intellectual property rights.
● Understand and comply with the regulations and conventions in relation to human rights recognised by the International Community.
● Ensure that fair employment opportunities are being offered and that recruitment, employment, and promotion of employees are based solely on individual talents, qualifications and achievements.
● Private information on employees shall be properly used, stored and transferred in line with the company’s related rules and the local country Data Protection laws. Privacy of employees must be respected.
● Understand and comply with the laws governing bribery and corruption in line with the company’s related policy. Bribery in any form is strictly prohibited.
● Understand and comply with laws and regulations governing environmental protection, health and safety; create and maintain a safe working environment.
● In the event of any conflict between the laws applicable to two or more countries, be sure to consult the Legal Department and make sure how to deal with such conflict properly.
Protecting Huawei Assets
It is fraudulent to prepare false contracts or relevant business documents, steal property from the Company, intentionally claim private expenses, make double claims for a single expense or report false account. Technology and trade secrets are Huawei’s most important assets and it is the duty of all the Company’s employees to protect all the physical assets, financial assets, information assets and other invisible assets in the possession of Huawei. If an employee suspects that information is being disclosed by a third party, they have a duty to report the breach to their immediate supervisor or the authority concerned.
Protecting Intellectual Property Rights (IPR)
Huawei Intellectual Property Rights include without limitation patents, trademarks, copyrights, trade secrets and other proprietary information. Employees must observe Huawei information security policies, protect and use Huawei intellectual property rights according to law.
Employees should not disclose any confidential information. Where the employee is unsure in the case of IPR disclosure, he/she shall consult the Legal Department.
Financial Control
Employees shall observe the Company’s finance systems and approval procedures at all times. Employees must make concerted efforts to create a safe and efficient financial environment through their commitments to financial control.
● Be sure to claim for actually incurred expenses lawfully within the specified limit, and avoid any improper expense claim. Employees must provide accurate financial record, claim expenses in line with the financial policies and approval procedures.
● Where an employee’s financial submissions appear to be inconsistent, the issue will be raised with the employee’s line manager.
● Administrators in a new business department or an overseas organization with a few employees should establish appropriate financial procedures or control policies in time, to ensure the security of the Company’s funds.
Whistle Blowing
Any Huawei Staff Member who has a reasonable belief that a person has failed, is failing or is likely to fail to comply with a particular legal, obligatory or regulatory obligation – for the purposes of this Business Code of Conduct this include a breach of this Business Code of Conduct, the Anti-Bribery and Corruption Policy, or the Gifts and Hospitality Policy, should disclose the matter confidentially to the manager of the department in which they work. If the matter is more serious or if you feel your concern has not been addressed, or if you prefer not to raise it with them for any reason, you should contact Huawei’s Compliance Officer or the General Manager. You may also raise the matter anonymously to the following addresses:
Email: Whistle4HWSE@huawei.com (Local) or BCGcomplain@huawei.com (Global)
Phone: +46(0)739200846
Huawei will always ensure that no Staff member will be subjected to any detriment or less favorable treatment for refusing to engage in or reporting in good faith any actual or suspected questionable conduct. The Staff are referred to Huawei’s Whistleblower Policy (which is published on website: https://consumer.huawei.com/se/ and may be updated from time to time and may be provided upon request by HR）for further guidance.