Received by NSD/FARA Registration Unit 03/20/2019 5:37:35 PM GMB No. 1124-0006; Expires May 31, 2020 u.s. Department of Justice Exhibit A to Registration Statement Pursuant to the Foreign Agents Registration Act of 1938, as amended washingion. dc 20530 INSTRUCTIONS. Furnish this exhibit for EACH foreign principal listed in an initial statement and for EACH additional foreign principal acquired subsequently. The filing of this document requires the payment of a filing fee as set forth in Rule (d)(1), 28 C.F.R. § 5.5(dX*1)- Compliance is accomplished by filing an electronic Exhibit A form at hups/m w\v luni.L>o\ . Privacy Act Statement-' Thefiling of this document is required by the Foreign Agents Registration Act of 1938, as amended, 22 U.S.C. § 611 etseq., for the purposes of registration under the Act and public disclosure. Provision of the information requested is mandatory, and failure to provide this information is subject to the penalty and enforcement provisions established in Section 8 of the Act. Every registration statement, short form registration statement, supplemental statement, exhibit, amendment, copy of informational materials or other document or information filed with the Attorney General under this Actis a public record open to public examination, inspection and copying during the posted business hours of the ' Registration Unit in Washington, DC. Statements are also available onlihe at the Registration Unit’s webpage: l»itps:#wwiv,fara.go\vOne copy of every such document, other than informational materials, is automatically provided to the Secretary of State pursuant to Section 6(b) Of the Act, and copies of any and all documents arc routinely made available io other agencies, departments and Congress pursuant to Section 6(c) of the Act. The Attorney General also transmits a Semi-annual report to Congress on the administration of the Act which lists the names of all agents registered under the Act and the foreign principals they represent. This report is available to the public iii print and online at: https://mvw.far,i.gm-. Public Reporting Burden. Public reporting burden for this collection Of information is estimated to average .49 hours per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing mid reviewing the collection of information. Send comments regarding this burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden to Chief Registration Unit, Counterintelligence and Export Control Section, National Security Division, O.S. Department of Justice, Washington, DC 20530; and to the Office of Information and Regulatory Affairs, Office of Management and Budget, Washington, DC 20503. 2, Registration No, I. Name and Address of Registrant BCWLLC 1110 Vermont Ave., N.W. Suite 1200 Washington, D.C. 20005 6227 3. Name of Foreign Principal 4. Principal Address of Foreign Principal Huawei Technologies Co. Ltd. (via BCW Asia Pacific) Huawei Technologies Co. Ltd. BCW Asia Pacific Bantian Huawei Base 23/F Chinachem Exchange Square Longgang District 1 Hoi Wan Street, Quarry Bay Shenzhen, 518129 China Hong Kong SAR Hong Kong 5. Indicate whether your foreign principal is one of the following: □ Government of a foreign country 1 □ Foreign political party 0 Foreign or domestic organization: If either, check one of the following: □ Partnership □ Committee 0 Corporation □ -Voluntary group □ Other (specify) P Association □ Individual-State nationality ________ ■ ._______ ________________ ................................... ■ - 1 .......................................... 6. If the foreign principal is a foreign government, state: a) Branch or agency represented by the registrant N/A b) Name and title of official with whom registrant deals j N/A 7. If the foreign principal is a foreign political party, state: a) Principal address N/A b) Name and title of official with whom registrant deals c) Principal aim N/A N/A 1 "Government of a foreign country," as defined in Section 1(e) of the Act, i ncludes any person or group of persons exercising sovereign dc facto or de jure political jurisdiction over any country, other than the United States, or over any pan of such counliy. and includes tiny subdivision of any such group and any group or agency to which such sovereign de lacto or de jure authority or functions are directly or indirectly delegated. Such term shall include any (action or body of insurgents within a country assuming to exercise governmental authority whether such faction or body of insurgents has or has not been recognized by Ihe United States, FORM NSD-3 Revised 05/17 Received by NSD/FARA Registration Unit 03/20/2019 5:37:35 PM 8. If the foreign principal is not a foreign government or a foreign political party: a) State the nature of the business or activity of this foreign principal, telecommunications equipment manufacturer. b) Is this foreign principal: Supervised by a foreign government, foreign political party, or other foreign principal Yes D No 0 Owned by a foreign government, foreign political party, or other foreign principal Yes □ No S Directed by a foreign government, foreign political party, or other foreign principal Yes □ No 0 Controlled by a foreign government, foreign political party, or other foreign principal Yes □ No g Financed by a foreign government, foreign political party, or other foreign principal Yes □ No Subsidized in part by a foreign government, foreign political party, or other foreign principal Yes □ No S IS) 9, Explain fully all items answered "Yes" in Item 8(b). (Ifadditional space is needed, afull insert page must be used) N/A 10. If the foreign principal is an organization and is not owned or controlled by a foreign government, foreign political party or other foreign principal, state who owns and controls it. It is our understanding that Huawei Technologies Co. Ltd. is a private, employee-owned company. That understanding and our responses to Question 8(b) above are based on publicly available information. We have requested, but have not obtained, confirmation of this information from Huawei. EXECUTION In accordance with 28 U.S.C. § 1746, the undersigned swears or affirms under penalty of peijury that he/she has read the information set forth in this Exhibit A to the registration statement and that he/she is familiar with the contents thereof and that such contents are in their entirety true and accurate to the best of his/her knowledge and belief. Date of Exhibit A Name and Title tu re Received bv NSD/FARA Registration Unit 03/20/2019 5:37:35 PM Received by NSD/FARA Registration Unit 03/20/2019 5:37:32 PM OMB No. 1124-0004; Expires May 31, 2020 Exhibit B to Registration Statement Pursuant to the Foreign Agents Registration Act of 1938, as amended u.s. Department of Justice Washington, dc 20530 INSTRUCTIONS. A registrant must furnish as an Exhibit 6 copies of each written' agreement and the terms and conditions of each oral agreement With his foreign principal, including all modifications of such agreements, or, where ho contract exists, a full statement of all the circumstances by reason of which the registrant is acting as an agent of a foreign principal. Compliance is accomplished by filing an electronic Exhibit B form at hitps:/A\u\'. Iimi.gov. Privacy Act Statement, The filing of this document is required for the Foreign Agents Registration Act of 1938, as amended, 22 U.S.C. § 611 etseq., for the purposes of registration under the Act and public disclosure. Provision of the information requested is mandatory, and failure to provide the information is subject to the penalty and enforcement provisions established in Section 8 of the Act. Every registration statement, short form registration statement, supplemental statement, exhibit, amendment, copy of informational materials or other document or information filed with the Attorney General under this Act is a public record open to public examination, inspection and copying during the posted business hours of the Registration Unit in Washington, DC. Statements arc also available online at the Registration Unit’s webpage: hiips/Atwu-.raru.gov. One copy of every such document, other than informational materials, is automatically provided to the Secretary OfState pursuant to Section 6(b) of the Act, and copies of any and all documents are routinely made available to other agencies, departments and Congress pursuant to Section 6(c) of the Act. The Attorney General also transmits a semi-annual report to Congress on the administration of the Act which lists the names of all agents registered under the Act and the foreign principals they represent. This report is available to the public in print and online at:- hupectfww w.ianr.gov. Public Reporting Burden. Public reporting burden for this Collection of information is estimated to average .33 hours per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. Send comments regarding this burden estimate or any other aspect of this collection Of information, including suggestions for reducing this burden to Chief, Registration Unit, Counterintelligence and Export Control Section, National Security Division. U.S. Department of Justice. Washington, DC 20530; and to the Office of Information and Regulatory Affairs, Office of Management and Budget, Washington, DC 20503. 2. Registration No. 1. Name of Registrant 6227 BCW LLC 3. Name of Foreign Principal Huawei Technologies Co. Ltd. (via BCW Asia Pacific) Check Appropriate Box: 4. lx) The agreement between the registrant and the above-named foreign principal is a formal written contract. If this box is checked, attach a copy of the contract to this exhibit. 5. □ There is no formal written contract between the registrant and the foreign principal. The agreement with the above-named foreign principal has resulted from an exchange of correspondence. If this box is checked, attach a copy of all pertinent correspondence, including a copy of any init ial proposal which has been adopted by reference in such correspondence. 6. □ The agreement or understanding between the registrant and the foreign principal is the result of neither a formal written contract nor an exchange of correspondence between the parties. If this box is checked, give a complete description below of the terms and conditions of the oral agreement or understanding, its duration, the fees and expenses, if any, to be received. 7. Describe fully the nature and method of performance of the above indicated agreement or understanding. The nature and method of performance of the above-indicated agreement are set forth in the attached memorandum. Prior to memorializing the attached scope of work, BCW LLC commented on, but did not create or disseminate, a proposed ad vertisement for U.S. print media, which was published on February 28,2019. In addition, BCW LLC commissioned a public opinion research project using,polling and focus groups. FORM NSD.4 Revised 05/17 Received bv NSD/FARA Registration Unit 03/20/2019 5:37:32 PM Received by NSD/FARA Registration Unit 03/20/2019 5:37:32 PM Describe fully the activities the registrant engages in or proposes to engage in On behalf of the above foreign principal. 8. The nature and method of performance of the above-indicated agreement are set forth in the attached memorandum. 9. Will the activities on behalf of the above foreign principal include political activities as defined in Section l(oj of the Act and in the footnote below? Yes 0 No □ If yes, describe all such political activities indicating, among other things, the relations, interests or policies to be influenced together with the means to be employed to achieve this purpose. Provide strategic communications advice related to ongoing U.S. governmental and media inquiries into Huawei Technologies Co. Ltd. Please see attached memorandum for additional information. EXECUTION In accordance with 28 U.S.C. § 1746, the undersigned swears or affirms under penalty of perjury that he/she has read the information set forth in this Exhibit B to the registration statement and that he/she is familiar with the contents thereof and that such contents are in their entirety true and accurate to the best of his/her knowledge and belief. Date of Exhibit B Dtnot^ tom Name and Title Signa '***> Dc&> Footnote 'Tolitidal activity " as defined in Sectiftn ectiftn 1(b) l(o) of the Act, means any activity which the person ^Tgaging in believef*ill, or that the person intends 10, in any way influence any agency or official of the Government of the United Suites or any section of the public within the United States with reference to formulating, adopting, or changing the domestic or foreign policies of Ihe United Stales or with reference to the political or public interests, policies, or relations of a government of a foreign country or a foreign political parry Received bv NSD/FARA Registration Unit 03/20/2019 5:37:32 PM Receivecfby NSD/FARA Registration Unit 03/20/2019 5:37:32 PM From: Sent: To: Cc: Subject: Tuliy, Trevor Friday, March 8,2019 12:31 AM Balkam, Sharon Przybyski, Pat; Manyam, Shai la; Stafford, Matt; Wan, Jorrta Attachments: SOW for BCW DC Huawei - BCW DC SOW 022819 (final).pdf Follow Up Flag: Follow up Flag Status: Flagged Dear BCW DC: This email will serve as Intercompany Work Order to proceed with the scope of services as outlined in the attached document Huawei - BCW DC SOW 022819 (final) for a not to exceed budget of $160,000 for services commencing in February 2019. All invoices must reference Client/P reject Name, Requesting Office Client/Project Billing Code, Billing Period, Name of Requesting Office Client Leader 8i Financial Contact and must have a copy of this Work Order attached. Total invoiced must not exceed budget without an approved amendment to this Work Order. Invoices should be issued to Burson-Marsteller (Hong Kong) Ltd (BFC code BCWHK). Regards Trevor l ■Rec.eM_b.v_N.SIj/EARA.Rfeg.ktTation Unit...03/20/2019 5:37:32 PM Received by NSD/FARA Registration Unit 03/20/2019 5:37:32 PM 4§ ■)yy HUAWEi MEMO DATE: TO: FROM: RE: 28 February 2019 BCW APAC Office BCW DC Office Scope of Work We are delighted to partner with you to support Huawei in the United States. Following is a scope of work for the purposes of outlining anticipated requests for strategic counsel and other activities to protect* defend and promote Huawei’s reputation in the United States. In light of the special requirements associated with U.S. public-relations matters, all advice related to the U.S. market will be provided by personnel in BC W’s U.S. offices. I have included an estimate of anticipated billable hours per task, to be billed at crisis rates, where relevant. Please do not hesitate to contact me if you have any questions. 1. 10-Point US Strategic Plan • • • • Develop overall reputation strategy specific to US and issues. Develop messaging strategy and editorial calendar in coordination with partners and global teams Develop lists of targeted media, influencers, KOLs, business partners and advisory council members Refinements and edits as requested Total: $35,000 2. Media Counsel • and Recommendations • Recommend strategy and media targets for briefs and Huawei campus trips Provide strategic counsel and advice for media outreach initiatives in the United States, including campaign elements Hours Per Month: Managing Partner/Senior Counsel: 1 Senior Partner/MD: 2 Partner/SD: 3 AAE: 5 Received by NSD/FARA Registration Unit . 03/20/2019 5:37:32 PM Received by NSD/FARA Registration Unit 03/20/2019 5:37:32 PM 3. Research (conducted by • PSB) • • • Develop and deploy quick-turn opinion research to assess perceptions of Huawei and test initial messaging among audiences most relevant to issues facing Huawei Two focus groups to develop insights and test and refine key messages Final report with results, recommendations for next steps and key insights and briefing to clients Integration of research findings into strategy, messaging and content, including coordinating with partners. Total: $80,000 4, Reputation Strategy Counsel • Recommendations, strategy and consultation around actions taken by Huawei in the US, including but not limited to: legal actions, partnerships, outreach, influencer relations and partner relations. Hours Per Month: Managing Partner/Senior Counsel: 2 Senior Partner/MD: 3 Partner/SD: 3 5. Think Tank/KOL Counsel • • Identify and vet target key opinion leaders (KOL) most relevant to issues facing Huawei Develop US-focused KOL strategy and recommend targets for outreach Hours Per Month: Partner/SD: I Account Strategy and Coordination • • • Liaison with global teams, including Huawei leadership on KOL programs and other elements Coordination and briefing calls/meetings as needed with partners and client Account management, including coordination with Huawei on execution Hours Per Month: Partner/SD: 1 2 Received by NSD/FARA Registration Unit 03/20/2019 5:37:32 PM