Ethics, Compliance and Audit Services
UCOP Guidance: Presidential Request February 13, 2019 Huawei-ZTE Inventory
Due to the evolving legal and risk landscape as to Huawei and ZTE, and in particular the possibility of an executive order or placement on a government restricted parties list, pursuant to President Napolitano’s letter of February 7, 2019, and the first topline recommendation listed in Appendix 1, President Napolitano requests that campuses promptly take the following actions:
- Conduct a full and complete inventory as to (1) all equipment and services provided by Huawei and ZTE to your location; (2) any gift funds provided by Huawei or ZTE to your location during the past five years; (3) any grant funds or other research support provided by Huawei and ZTE to your location during the past five years; and (4) any other support provided by Huawei or ZTE to your location for any educational or research programs for the past five years. Such inventories should not be limited to equipment or services that would be prohibited by the NDAA, grant or gift funds that would be reportable under the HEA, or grant funds or research support that would fall under the fundamental research exclusion.
- Collect any and all contracts or agreements with Huawei and ZTE concerning any of the three categories set forth in the above point and analyze their expiration, termination, and renewal provisions so that expedited decisions can be made in the event of government action.
- Consider whether major or critical equipment or services currently provided by Huawei or ZTE (and in particular such equipment or services that could fall within the ND.AA prohibitions) can be removed and replaced with equipment or services provided by another entity, analyze risks and impediments to such removal and replacement, and formulate response plans in case of adverse government action.
For further clarification, please see the FAQs.
Please send your inventories to Senior Vice President and Chief Compliance & Audit Officer Alexander Bustamante at ECAS@ucop.edu no later than March 15, 2019.