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CHINA
SIGNPOSTS:
A
PRACTICAL
GUIDE
FOR
MULTINATIONALS
IN
2022
CHINA
SIGNPOSTS:
A PRACTICAL GUIDE
FOR MULTINATIONALS
IN 2022
CHINA
SIGNPOSTS:
A
PRACTICAL
GUIDE
FOR
MULTINATIONALS
IN
2022
2
CONTENTS
GLOBAL VIEWPOINTS
ISSUES THAT WILL DEFINE THE OPERATING ENVIRONMENT
U.S.-China Relations – James McGregor ............................................................................................................4
EU-China Relations – Declan Kelleher .................................................................................................................5
UK-China Relations – Richard Burn ......................................................................................................................6
Global Trade and Technology Competition – Pamela Passman .....................................................................7
China Signposts is an annual
guide by APCO Worldwide
for executives of multinational
companies (MNC) that have
significant China interests, whether
as a key market for sales, as a
critical supplier, or as a source of
innovation and competition.
This guide identifies seven issues
that will be critical for MNCs to
navigate in 2022 and offers global
viewpoints from several of APCO’s
senior advisors.
SECURITY & DATA:
DRIVING FORCES BEHIND POLICYMAKING ......................................................................................................9
DUAL CIRCULATION:
UPGRADING “IN CHINA, FOR CHINA” .............................................................................................................10
COMMON PROSPERITY:
EXPANDING THE PIE ...........................................................................................................................................11
REGULATORY REFORM:
REMOVING BARRIERS TO ACHIEVE ECONOMIC REBALANCING ...............................................................12
TRADE AND SUPPLY CHAINS:
CAUGHT IN THE CROSSFIRE ..............................................................................................................................13
COVID-19:
SMALL GLIMMERS OF HOPE ..............................................................................................................................14
ENVIRONMENT & ENERGY:
STARTING THE LONG MARCH TOWARDS DECARBONIZATION .................................................................15
CHINA
SIGNPOSTS:
A
PRACTICAL
GUIDE
FOR
MULTINATIONALS
IN
2022
GLOBAL
VIEWPOINTS
CHINA
SIGNPOSTS:
A
PRACTICAL
GUIDE
FOR
MULTINATIONALS
IN
2022
4
mechanisms to foster corporate cohesion, culture and connection.
Corporate leaders must prioritize direct engagement with their China
teams to better understand their interpretations of sensitive issues
and on-the-ground operating dynamics.
The Era of Quiet Compliance:
Despite impulses to speak out on topics of social justice and ESG,
businesses with a China presence must exercise caution. Compliance
with regulations and interactions with public officials in Washington,
Brussels or Beijing should be executed without fanfare to avoid
inadvertently provoking nationalist reactions and risking reputational
and operational challenges.
U.S.-China Relations
James McGregor
APCO Greater China Chairman
and bestselling author
A New Normal for Business:
The first year of the Biden administration revealed that the Trump
era of confrontation was not an anomaly. In 2022, the United States
will continue to pressure China on allegations of unfair economic
practices and human rights abuses, particularly ahead of the U.S.
midterm elections and in the wake of the Beijing Winter Olympics.
China and the United States will pressure companies to speak out
against their counterparts’ most assertive policies. The United States
also seeks greater policy coordination with its allies in Europe, the
Quad and AUKUS.
Fraying Links Between HQ and China:
COVID-19 travel restrictions are widening the disconnect between
headquarters and China management teams. There are ample
opportunities for foreign enterprises to continue growing their China
businesses in 2022, but global executives will need to entrust this
growth to their on-the-ground leadership teams and strengthen
...global executives will need
to entrust this growth to their
on-the-ground leadership teams
and strengthen mechanisms
to foster corporate cohesion,
culture and connection.
...the Trump era of confrontation
was not an anomaly.
GLOBAL VIEWPOINTS
4
CHINA
SIGNPOSTS:
A
PRACTICAL
GUIDE
FOR
MULTINATIONALS
IN
2022
5
areas such as health, industrial and foreign policy. Businesses should
keenly track the views of influential member states and of coalitions
of member states on key issues. While EU member states may
sometimes have differing opinions on China-related issues, the legal
force and influence of agreed EU regulation (the “Brussels effect”)
need to be factored in by European and non-EU businesses.
Top-down Guidance:
In the sensitive period before the 20th
National Communist Party
Congress in November, headquarters executives need to be
particularly aware of top-down political guidance within China.
Evolving policy prescriptions and regulations on economic,
social, and environ-mental issues, as well as re-castings of core
Party ideology and policy—such as the Common Prosperity
agenda—present both challenges and opportunities for business.
EU businesses should be mindful of potential challenges to resolving
divergent compliance requirements of China on the one hand, and
EU and national authorities on the other.
GLOBAL VIEWPOINTS
EU-China Relations
Declan Kelleher
Former Ambassador of Ireland to
the People’s Republic of China and
Permanent Representative of
Ireland to the European Union
Nuance in Geopolitics:
Geopolitical uncertainties, the pandemic, fears for the health of
the liberal rules-based international order and concerns that the
EU should be less vulnerable and more realistic on trade, have led
the EU to fashion a more multifaceted and rigorous approach to
engagement with China without necessarily containing it. While
the EU will undoubtedly seek to work closely with the Biden
administration on certain aspects of China policy, the evolving
concept of EU “strategic autonomy” will influence the shape of
this cooperation. In 2022, whether the EU can manage political and
values-based differences with China will determine the scope of
defrosting the EU-China Comprehensive Agreement on Investment
(CAI). The European Parliament will play a significant role in dictating
whether this thaw will occur.
Working with the Grain:
The EU legislative process involves three parties: the Commission,
the Council (the member states) and the European Parliament.
Some areas, such as trade policy, are the exclusive competence of
the Commission, while national authorities have a stronger say in
...headquarters executives
need to be particularly aware of
top-down political guidance...
Businesses should keenly track the
views of influential member states...
5
CHINA
SIGNPOSTS:
A
PRACTICAL
GUIDE
FOR
MULTINATIONALS
IN
2022
6
weaknesses and the need to appease a small yet important group of
Conservative Party backbench parliamentarians pushing for a more
hawkish position towards Beijing. The saga of Chinese interference in
UK politics is illustrative of a growing sensitivity and hostility towards
China among UK Members of Parliament.
Transparency Is Key:
Businesses involved in critical infrastructure are most at risk of
the reporting and investigation requirements under the UK’s new
National Security and Investment (NSI) Act, though the vast majority
of businesses need not worry. But all businesses should expect a
greater emphasis on transparency: Chinese businesses on their
activities in the UK and British MNCs on their business in China.
Stabilizing the Decline:
While the UK-China relationship has deteriorated from its “golden
era,” it remains fundamentally stable. The UK government
simultaneously shares the concern of the United States, the EU and
others on human rights, while also recognizing that a constructive
relationship with China is pivotal for trade and investment.
While businesses can categorically rule out a return to free trade
negotiations in 2022, MNCs may witness the long overdue return of
the UK-China Economic & Financial Dialogue (EFD) and the Joint
Economic and Trade Committee (JETCO), which has not been held
since 2018.
Managing Vocal Opposition:
Boris Johnson has been the driving force behind a delicate balancing
act, but he has been constrained by COVID-19, his own political
GLOBAL VIEWPOINTS
UK-China Relations
Richard Burn
Former HM Trade Commissioner for
China and HM Trade Commissioner
for Europe
The saga of Chinese interference
in UK politics is illustrative of a
growing sensitivity and hostility
towards China among UK Members
of Parliament.
...MNCs may witness the long
overdue return of the UK-China
Economic & Financial Dialogue
(EFD) and the Joint Economic and
Trade Committee (JETCO)...
6
CHINA
SIGNPOSTS:
A
PRACTICAL
GUIDE
FOR
MULTINATIONALS
IN
2022
7
Diversifying and De-risking Global
Supply Chains:
In 2022, growing pressures to decouple combined with rising
expectations for businesses to act on contentious social and climate
issues and disruptions caused by COVID-19 require multinationals
to reassess and reconfigure their global supply chain. Cost-efficiency
should no longer be the leading factor for how companies source
or locate their manufacturing. Multinationals need to think about
diversifying supply chain risks—whether through “multi-shoring” or
building a “plug and play” manufacturing model—depending on
whether and what they will sell in China, the United States or third
markets. This will help enhance their overall supply chain resilience
against headwinds while allowing them to maintain a strong
presence in China—fundamental for businesses that want to remain
competitive globally.
Pamela Passman
Chair of Corporate and Managing
Director, New York, and former Deputy
General Counsel at Microsoft
The “Decoupling” Dilemma:
Strategic competition between the United States and China over
global technology dominance will increase pressure for businesses
to “decouple,” particularly in areas that are perceived as critical to
national security such as data. Multinationals require access to cloud
services, interoperable technologies and critical business information
across markets to innovate and operate efficiently. Creating artificial
walls and data friction is inherently counterproductive to innovation,
trade, and growth. In 2022, it will be incumbent upon global
companies to work with policymakers to help them understand the
practical implications and costs of decoupling.
Multinationals need to think about
diversifying supply chain risks—
whether through “multi-shoring”
or building a “plug and play”
manufacturing model...
...it will be incumbent upon
global companies to work with
policymakers to help them
understand the practical implications
and costs of decoupling.
GLOBAL VIEWPOINTS
Global Trade and
Technology Competition
7
CHINA
SIGNPOSTS:
A
PRACTICAL
GUIDE
FOR
MULTINATIONALS
IN
2022
ISSUES THAT WILL
DEFINE THE OPERATING
ENVIRONMENT
SIGNPOSTS FOR 2022:
CHINA
SIGNPOSTS:
A
PRACTICAL
GUIDE
FOR
MULTINATIONALS
IN
2022
9
Security will dominate China’s 2022 political agenda ahead of the
forthcoming 20th
National Communist Party Congress. Ensuring
Xi Jinping’s unquestioned reappointment as Party Secretary will
be the Party’s utmost priority.
MNCs should keep a low profile and focus on compliance with
a raft of new laws and regulations, including the Data Security
Law and the Personal Information Protection Law, which aim to
protect citizens and bring stability to markets.
Equally, MNCs should not make bold or dramatic moves ahead
of the Party Congress and should not anticipate significant new
policies related to opening and deregulation in 2022.
In strategically important sectors, government industrial policy
will support and offer subsidies to domestic champions.
MNCs must audit themselves to avoid crosscutting
national security hotspots—whether political,
ideological, economic or technological.
SECURITY & DATA:
DRIVING FORCES
BEHIND POLICYMAKING
Ongoing geopolitical tensions and the
upcoming 20th
National Communist Party
Congress make 2022 a critical year for China.
This period of acute political sensitivity is
cementing a risk-averse mindset within
government to mitigate economic instability.
From addressing the risk of food and
resource shortages to ensuring control over
strategic sectors, all policy decisions will have
strategic significance in 2022. Within this
environment, MNCs should exercise extreme
caution when deciding how to handle
sensitive matters that could intersect with
China’s long-term interests.
MNCs must prepare for a greater emphasis
on cybersecurity and data issues in 2022.
Enforcing the privacy-oriented Personal
Information Protection Law (PIPL) and the
national security-oriented Data Security Law
(DSL) is already underway. If not already
completed, MNCs should compare their
compliance with the EU GDPR in developing
mechanisms to adhere to the PIPL. MNCs
operating in sensitive areas, including
e-commerce, healthcare and automotive
sectors, should anticipate increased
government scrutiny under the DSL.
MNCs should mind China’s long-term focus
on “technology self-reliance”—a central
pillar of China’s national security strategy.
Increasing state support for domestic
competitors is an irreversible trend; MNCs
hoping to grow in China will need to
demonstrate how they support China’s
global competitiveness.
CHINA
SIGNPOSTS:
A
PRACTICAL
GUIDE
FOR
MULTINATIONALS
IN
2022
10
Chinese economic and industrial policies reinforce the need for
self-reliance, but Dual Circulation still requires MNC innovation,
expertise and export markets.
Building more resilient corporate structures should be a
priority for 2022. This will include reviewing local partnerships,
investments, procurement relationships and product
development arrangements.
Such a review should help accelerate China market growth,
insulate global and local operations against geopolitical risks
and protect against other external shocks.
Businesses that double down on their
commitments to China, while creating strategic
separation from their parent entities, will be
most resilient and best placed for growth.
DUAL CIRCULATION:
UPGRADING “IN CHINA,
FOR CHINA”
One of Beijing’s responses to geopolitical
friction is to take actions that make China
less dependent on the world, but make the
world more dependent on China. This “Dual
Circulation” strategy seeks to insulate China
from the unstable ebbs and flows of the
global economy and place its own economic
destiny firmly in its own hands.
This strategy seeks to elevate the Chinese
consumer to become the bedrock of its
economy, empowering domestic companies
and enhancing local supply chain resilience.
Beijing also wants to reduce dependence on
export markets and limit the impact of U.S.
and foreign government actions to stymie
access to the critical technologies essential
to China’s development.
While this undoubtedly means greater
support for domestic entities, especially
Chinese companies in critical sectors,
this does not mean foreign companies
are unwelcome in China. Instead, Beijing
wants foreign businesses to occupy specific
roles within the market and contribute to
“Dual Circulation.”
Regardless of past experience, MNCs need
a thorough rethink of what it means to be
“in China, for China.” Treating China as a
“client” for products or a “source” for global
markets is no longer enough. Those with
market access are increasingly expected to
demonstrate how their presence empowers
domestic innovation, strengthens domestic
supply chains and adheres to social and
political priorities. This can be done through
value chain partnerships, investments or
localizing R&D to develop products for
global markets, or “in China for the world.”
This will have profound implications for the
structure of MNCs. While some are localizing
data to ensure compliance and build trust,
others already treat China as a second home
market—complete with parallel operations
and a full value chain. Creating this firewall
may protect MNCs from geopolitical
turbulence and contradictory orders issued
by different national governments.
CHINA
SIGNPOSTS:
A
PRACTICAL
GUIDE
FOR
MULTINATIONALS
IN
2022
11
China’s growing middle class is demanding higher quality products
and services and pushing back against systemic economic injustices.
MNCs that employ and serve the needs of underdeveloped regions
and underserved populations in China are uniquely poised to secure
new opportunities.
Common prosperity is consistent with decades of Party doctrine
and articulates an expectation that all companies—foreign and
domestic—increase their commitments to give back to society and
encourage CSR, philanthropy and stakeholder capitalism.
MNCs should look for areas of alignment and
intersection with the Common Prosperity agenda,
a set of long-term goals which aim to address
China’s socioeconomic inequality and establish a
more sustainable socialist development model.
COMMON PROSPERITY:
EXPANDING
THE PIE
While Common Prosperity has been framed
as a new initiative, it is merely a new label
for a set of long-term goals. It is closely
aligned with the Chinese government’s other
long-standing priorities, such as transitioning
from high quantity to high-quality growth,
expanding the middle class through poverty
alleviation and rural revitalization and
promoting social and economic fairness.
Despite misconceptions, Common
Prosperity does not discourage businesses
and individuals from getting rich. Instead,
the government expects the wealthy to
inspire and play a greater role in supporting
marginalized groups through corporate
social responsibility and philanthropic efforts.
The government will adopt a wide range of
measures to achieve Common Prosperity.
In the short-term, businesses should expect
the introduction of new regulations and
increased scrutiny in certain sectors—such as
technology, real estate and education—
to ensure more fair market practices and
equal market access for all.
In the medium and long-term, central
and local authorities will focus initiatives
on ensuring access to basic social
welfare such as education and healthcare
for low-income groups, particularly in
rural and underdeveloped areas. The
government is also toying with tax
reform—including piloting property tax
schemes in certain areas—to facilitate
a more equal income distribution. The
government may also increase personal
income and consumption taxes that will
mainly affect high-income groups.
CHINA
SIGNPOSTS:
A
PRACTICAL
GUIDE
FOR
MULTINATIONALS
IN
2022
12
Domestic reforms to promote China’s economic stability will
create short-term volatility for businesses.
MNCs with Chinese partners or investments in the internet
sector, real estate and other high-risk industries should be alert
to potential regulatory spillover into their operations.
MNCs can continue to find opportunities in critical sectors where
China still requires global expertise and knowledge—particularly
in financial services, advanced manufacturing and technology.
Beijing’s efforts to mitigate near-term financial
risks present an opportunity for foreign MNCs,
particularly if they can align with the Party’s long
sought economic restructuring.
REGULATORY REFORM:
REMOVING BARRIERS TO ACHIEVE
ECONOMIC REBALANCING
The focus on maintaining Chinese economic
stability means regulatory decisions will be
highly surgical in 2022. As a result, measures
will focus on stabilizing the real economy
while also creating a more robust economy
needed in the long-term. MNCs should
therefore expect a two-pronged approach:
a regulatory tightening in areas considered
as “social ills,” and a targeted opening-up in
sectors in need of a structural economic shift.
The government’s scrutiny of monopolistic
behavior, especially surrounding data and
algorithms, will continue at pace. Reforms
are likely to continue in China’s financial
and capital markets. In light of China’s latest
property sector crisis, Beijing faces immense
pressure to contain systematic financial
risk by curbing debt and excessively risky
offshore investments, and targeting illicit
cross-border transactions.
The need to improve the efficiency of the
Chinese financial sector is also pushing
Beijing to look outward. Officials seek
trusted players that can provide the jolt
(and capital) required to not only establish
a well-functioning financial system, but also
underwrite the critical industries needed for
its long-term development goals. Foreign
financial institutions may find significant
opportunities to deepen their participation
in China. These opportunities, however, may
also present new risks for MNCs, such as
a potential “spillover effect” of a Chinese
regulatory crackdown for foreign firms.
CHINA
SIGNPOSTS:
A
PRACTICAL
GUIDE
FOR
MULTINATIONALS
IN
2022
13
Trade is an increasingly important tool in the geopolitical toolboxes
of Western countries as they address allegations against China’s
human rights practices. Beijing will also use coercive economic
measures in response to foreign actions on issues it views as key to
China’s sovereignty.
Western countries will not subordinate human rights allegations
in China to economic or trade interests. While the Beijing Winter
Olympics will be a flashpoint, policymaking in this area will continue
throughout 2022.
MNCs will increasingly be expected to have visibility into their entire
supply chain. All companies should already be focused on auditing,
diversifying and de-risking.
As MNCs navigate the consequences of geopolitical
and trade issues, home nation governments and
the Chinese government will both increasingly
expect extraterritorial compliance—for companies
to uphold their own country’s values in every
jurisdiction where they operate.
TRADE & SUPPLY CHAINS:
CAUGHT IN
THE CROSSFIRE
China’s bids for bilateral trade agreements
have stalled. Two years after the U.S.-China
Phase I Agreement, bilateral trade relations
remain poor as China has failed to meet
purchasing commitments and the Biden
administration maintained or upgraded
several Trump-era enforcement actions.
Just one year after the EU-China
Comprehensive Agreement on Investment
(CAI), ratification is on ice aafter China
implemented sanctions against EU officials
due to their stance on Xinjiang. Chinese
coercive economic measures against smaller
EU states over Taiwan further complicate its
resuscitation in 2022.
As brute force proves less effective in
shaping international affairs, countries are
increasingly defaulting to wielding their
markets and economic influence
to encourage strategic rivals to change
their behavior.
MNCs will continue to face greater
compliance requirements as trade policy
and domestic agendas align on human
rights. In Washington, the new Uyghur
Forced Labor Prevention Act entering into
force in mid-2022 will require companies to
prove imports from Xinjiang are free from
forced labor. While the EU Commission may
have postponed the release of its proposed
human rights and environmental due
diligence directive, some EU member states,
such as Germany and the Netherlands, are
forging ahead with mandatory due diligence
requirements of their own.
Chinese officials will likely balance
projections of domestic strength with
economic stability. MNCs need to watch
for Chinese countermeasures deployed in
response to Western government actions
on human rights. As these may single
out specific industries or companies,
headquarters should be in lockstep with
in-country leadership to ensure alignment.
Establishing and maintaining good
working relationships with local officials
and regulators where companies have a
significant presence is more essential
than ever.
CHINA
SIGNPOSTS:
A
PRACTICAL
GUIDE
FOR
MULTINATIONALS
IN
2022
14
The political significance of this year for the Party lowers
the chance that COVID-19 restrictions will be completely lifted
in 2022.
Headquarters will need to rely more than ever on their in-
country presence or local partnerships to run their businesses
and supply chains.
Maintaining trust and managing through the opacity caused by
the physical and information divide will become increasingly
essential for business and supply chain continuity.
Border restrictions and other COVID
measures will frustrate MNCs that operate
inside and outside of China, demanding new
strategies for coordination between
headquarters and local management.
COVID-19:
SMALL GLIMMERS
OF HOPE
With the Winter Olympics and the 20th
National Communist Party Congress taking
place in Beijing this year, China is very likely
to maintain its zero-COVID-19 policy and
impose local lockdowns whenever needed.
This zero-tolerance strategy may chafe
against the government’s urgent need to
reverse slowing economic growth caused by
sudden restrictions. The sole silver lining is
in manufacturing, where government efforts
to preserve economic growth will result in
minimizing disruptions to production as
much as possible.
In-person engagement with government
officials will only be possible for those based
in China. MNCs with a strong in-country
presence should take advantage of this,
empowering local teams to make their
presence felt and commitment to China
known. Those lacking boots on the ground
will need to maintain and refresh alternative
strategies and intermediaries, whether
finding a reliable partner or investing in
relationships virtually where possible.
The ability to move staff in and out of
China will remain severely limited in 2022,
meaning the ability of MNCs to execute
mission-critical business decisions may be
delayed. In the absence of details on an
upgraded fast track for U.S.-China business
travelers and continued uncertainty in
China on the Omicron variant, companies
will be challenged to strengthen their
communication channels to minimize the
widening information gaps between China
and headquarters. This will prove critical in
responding quickly to emergency situations,
such as the impact of localized lockdowns,
to maintain business continuity and ensure
employee well-being.
CHINA
SIGNPOSTS:
A
PRACTICAL
GUIDE
FOR
MULTINATIONALS
IN
2022
15
Heightened environmental compliance pressures and regulatory
change require MNCs to closely monitor policies and trends to
enable well-informed business decisions.
Companies should anticipate and proactively adapt to forthcoming
changes to minimize business disruption.
Green development creates business transformation and
reputation-building opportunities for MNCs who can bring
innovative technical solutions and practices to China.
Businesses need to assess the resilience of their
long-term sustainability plans, stay ahead of a
raft of new compliance requirements and seize
opportunities which align with Beijing’s climate and
environmental objectives.
ENVIRONMENT & ENERGY:
STARTING THE LONG MARCH
TOWARDS DECARBONIZATION
President Xi Jinping’s announcement of
China’s decarbonization goals casts a
long shadow over future environmental
policymaking. The emergence of a long-
term national framework to oversee
decarbonization in the coming decades
is instructive of China’s ambitious time-
lines, and is already being matched by a
wave of supportive policies at the central
and local levels.
In some parts of Eastern China and areas
surrounding Beijing, pollution standards
are now higher than similar regulations in
Western Europe and North America.
While resource constraints caused by global
shortages and the transition away from
coal may temporarily relax some emissions
standards in 2022, the overall trend will move
towards stricter standards in the near future.
MNCs will need to consider whether their
transition plans are future proof to withstand
long-term compliance rather than piecemeal
investments to meet current standards.
China’s sustainable transition also creates
opportunities for foreign companies to
improve their sustainability performance in
China and demonstrate value. Techno-
logical innovation will be essential to
minimizing the economic impact of this
transition and achieving China’s long-term
environmental objectives.
While the government will likely turn to
stimulus to incentivize the green transition,
a lack of domestic expertise remains a major
barrier. MNCs with a strong sustainability
commitment are well positioned to introduce
global standards and advanced practices in
key areas, such as supply chain management,
sustainable consumption, renewable energy,
green infrastructure and smart transportation.
These contributions can demonstrate
commitment to development goals and
provide a platform to institutionalize
engagement with key stakeholders and
industry partners.
CHINA
SIGNPOSTS:
A
PRACTICAL
GUIDE
FOR
MULTINATIONALS
IN
2022
16
ABOUT APCO WORLDWIDE
APCO’S GLOBAL CHINA PRACTICE
CONTACTS CONTRIBUTORS
James Robinson
Global Lead, Geo-Commerce,
New York
jrobinson@apcoworldwide.com
Teresa Lu
Managing Director, Global China Practice,
Washington D.C.
tlu@apcoworldwide.com
Anne Wang
Chief Operating Officer, Greater China
qwang@apcoworldwide.com
Bruce Fu
Managing Director, Beijing
bfu@apcoworldwide.com
Jeff Astle
Managing Director, Shanghai
jastle@apcoworldwide.com
Anthony Marchese (London)
Yining Yuan (Beijing)
Lucas Browne (New York)
Ryan Morgan (Washington D.C.)
Shuang Shan (Beijing)
Vivian Zhu (Washington D.C.)
Nina Zholudeva (Shanghai)
Freda Zhang (New York)
Rosalind Reischer (Washington D.C.)
Justin Iannacone (Washington D.C.)
Aileen Kearney (London)
Alistair Burlinson (Shanghai)
Jane Zhuang (Shanghai)
APCO Worldwide is an advisory and advocacy communications consultancy. We partner with public and private sector
organizations to help them catalyze progress, act with agility and build reputations, relationships and solutions that enable
success. APCO is an independent and majority women-owned business.
APCO’s Global China Team advises leaders on their China market strategies and supports leading Chinese enterprises as
they expand globally. The team includes consultants throughout Europe, the United States and Asia and is part of APCO’s
trailblazing Geo-Commerce offering, which guides clients whose interests intersect geopolitics and commerce. The Global
China Practice complements APCO’s strong onshore business in China, which boasts more than 25 years of experience
supporting multinational clients on the ground in China from offices in Beijing, Shanghai and Hong Kong.

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China Signposts: A Practical Guide for Multinationals in 2022

  • 2. CHINA SIGNPOSTS: A PRACTICAL GUIDE FOR MULTINATIONALS IN 2022 2 CONTENTS GLOBAL VIEWPOINTS ISSUES THAT WILL DEFINE THE OPERATING ENVIRONMENT U.S.-China Relations – James McGregor ............................................................................................................4 EU-China Relations – Declan Kelleher .................................................................................................................5 UK-China Relations – Richard Burn ......................................................................................................................6 Global Trade and Technology Competition – Pamela Passman .....................................................................7 China Signposts is an annual guide by APCO Worldwide for executives of multinational companies (MNC) that have significant China interests, whether as a key market for sales, as a critical supplier, or as a source of innovation and competition. This guide identifies seven issues that will be critical for MNCs to navigate in 2022 and offers global viewpoints from several of APCO’s senior advisors. SECURITY & DATA: DRIVING FORCES BEHIND POLICYMAKING ......................................................................................................9 DUAL CIRCULATION: UPGRADING “IN CHINA, FOR CHINA” .............................................................................................................10 COMMON PROSPERITY: EXPANDING THE PIE ...........................................................................................................................................11 REGULATORY REFORM: REMOVING BARRIERS TO ACHIEVE ECONOMIC REBALANCING ...............................................................12 TRADE AND SUPPLY CHAINS: CAUGHT IN THE CROSSFIRE ..............................................................................................................................13 COVID-19: SMALL GLIMMERS OF HOPE ..............................................................................................................................14 ENVIRONMENT & ENERGY: STARTING THE LONG MARCH TOWARDS DECARBONIZATION .................................................................15
  • 4. CHINA SIGNPOSTS: A PRACTICAL GUIDE FOR MULTINATIONALS IN 2022 4 mechanisms to foster corporate cohesion, culture and connection. Corporate leaders must prioritize direct engagement with their China teams to better understand their interpretations of sensitive issues and on-the-ground operating dynamics. The Era of Quiet Compliance: Despite impulses to speak out on topics of social justice and ESG, businesses with a China presence must exercise caution. Compliance with regulations and interactions with public officials in Washington, Brussels or Beijing should be executed without fanfare to avoid inadvertently provoking nationalist reactions and risking reputational and operational challenges. U.S.-China Relations James McGregor APCO Greater China Chairman and bestselling author A New Normal for Business: The first year of the Biden administration revealed that the Trump era of confrontation was not an anomaly. In 2022, the United States will continue to pressure China on allegations of unfair economic practices and human rights abuses, particularly ahead of the U.S. midterm elections and in the wake of the Beijing Winter Olympics. China and the United States will pressure companies to speak out against their counterparts’ most assertive policies. The United States also seeks greater policy coordination with its allies in Europe, the Quad and AUKUS. Fraying Links Between HQ and China: COVID-19 travel restrictions are widening the disconnect between headquarters and China management teams. There are ample opportunities for foreign enterprises to continue growing their China businesses in 2022, but global executives will need to entrust this growth to their on-the-ground leadership teams and strengthen ...global executives will need to entrust this growth to their on-the-ground leadership teams and strengthen mechanisms to foster corporate cohesion, culture and connection. ...the Trump era of confrontation was not an anomaly. GLOBAL VIEWPOINTS 4
  • 5. CHINA SIGNPOSTS: A PRACTICAL GUIDE FOR MULTINATIONALS IN 2022 5 areas such as health, industrial and foreign policy. Businesses should keenly track the views of influential member states and of coalitions of member states on key issues. While EU member states may sometimes have differing opinions on China-related issues, the legal force and influence of agreed EU regulation (the “Brussels effect”) need to be factored in by European and non-EU businesses. Top-down Guidance: In the sensitive period before the 20th National Communist Party Congress in November, headquarters executives need to be particularly aware of top-down political guidance within China. Evolving policy prescriptions and regulations on economic, social, and environ-mental issues, as well as re-castings of core Party ideology and policy—such as the Common Prosperity agenda—present both challenges and opportunities for business. EU businesses should be mindful of potential challenges to resolving divergent compliance requirements of China on the one hand, and EU and national authorities on the other. GLOBAL VIEWPOINTS EU-China Relations Declan Kelleher Former Ambassador of Ireland to the People’s Republic of China and Permanent Representative of Ireland to the European Union Nuance in Geopolitics: Geopolitical uncertainties, the pandemic, fears for the health of the liberal rules-based international order and concerns that the EU should be less vulnerable and more realistic on trade, have led the EU to fashion a more multifaceted and rigorous approach to engagement with China without necessarily containing it. While the EU will undoubtedly seek to work closely with the Biden administration on certain aspects of China policy, the evolving concept of EU “strategic autonomy” will influence the shape of this cooperation. In 2022, whether the EU can manage political and values-based differences with China will determine the scope of defrosting the EU-China Comprehensive Agreement on Investment (CAI). The European Parliament will play a significant role in dictating whether this thaw will occur. Working with the Grain: The EU legislative process involves three parties: the Commission, the Council (the member states) and the European Parliament. Some areas, such as trade policy, are the exclusive competence of the Commission, while national authorities have a stronger say in ...headquarters executives need to be particularly aware of top-down political guidance... Businesses should keenly track the views of influential member states... 5
  • 6. CHINA SIGNPOSTS: A PRACTICAL GUIDE FOR MULTINATIONALS IN 2022 6 weaknesses and the need to appease a small yet important group of Conservative Party backbench parliamentarians pushing for a more hawkish position towards Beijing. The saga of Chinese interference in UK politics is illustrative of a growing sensitivity and hostility towards China among UK Members of Parliament. Transparency Is Key: Businesses involved in critical infrastructure are most at risk of the reporting and investigation requirements under the UK’s new National Security and Investment (NSI) Act, though the vast majority of businesses need not worry. But all businesses should expect a greater emphasis on transparency: Chinese businesses on their activities in the UK and British MNCs on their business in China. Stabilizing the Decline: While the UK-China relationship has deteriorated from its “golden era,” it remains fundamentally stable. The UK government simultaneously shares the concern of the United States, the EU and others on human rights, while also recognizing that a constructive relationship with China is pivotal for trade and investment. While businesses can categorically rule out a return to free trade negotiations in 2022, MNCs may witness the long overdue return of the UK-China Economic & Financial Dialogue (EFD) and the Joint Economic and Trade Committee (JETCO), which has not been held since 2018. Managing Vocal Opposition: Boris Johnson has been the driving force behind a delicate balancing act, but he has been constrained by COVID-19, his own political GLOBAL VIEWPOINTS UK-China Relations Richard Burn Former HM Trade Commissioner for China and HM Trade Commissioner for Europe The saga of Chinese interference in UK politics is illustrative of a growing sensitivity and hostility towards China among UK Members of Parliament. ...MNCs may witness the long overdue return of the UK-China Economic & Financial Dialogue (EFD) and the Joint Economic and Trade Committee (JETCO)... 6
  • 7. CHINA SIGNPOSTS: A PRACTICAL GUIDE FOR MULTINATIONALS IN 2022 7 Diversifying and De-risking Global Supply Chains: In 2022, growing pressures to decouple combined with rising expectations for businesses to act on contentious social and climate issues and disruptions caused by COVID-19 require multinationals to reassess and reconfigure their global supply chain. Cost-efficiency should no longer be the leading factor for how companies source or locate their manufacturing. Multinationals need to think about diversifying supply chain risks—whether through “multi-shoring” or building a “plug and play” manufacturing model—depending on whether and what they will sell in China, the United States or third markets. This will help enhance their overall supply chain resilience against headwinds while allowing them to maintain a strong presence in China—fundamental for businesses that want to remain competitive globally. Pamela Passman Chair of Corporate and Managing Director, New York, and former Deputy General Counsel at Microsoft The “Decoupling” Dilemma: Strategic competition between the United States and China over global technology dominance will increase pressure for businesses to “decouple,” particularly in areas that are perceived as critical to national security such as data. Multinationals require access to cloud services, interoperable technologies and critical business information across markets to innovate and operate efficiently. Creating artificial walls and data friction is inherently counterproductive to innovation, trade, and growth. In 2022, it will be incumbent upon global companies to work with policymakers to help them understand the practical implications and costs of decoupling. Multinationals need to think about diversifying supply chain risks— whether through “multi-shoring” or building a “plug and play” manufacturing model... ...it will be incumbent upon global companies to work with policymakers to help them understand the practical implications and costs of decoupling. GLOBAL VIEWPOINTS Global Trade and Technology Competition 7
  • 9. CHINA SIGNPOSTS: A PRACTICAL GUIDE FOR MULTINATIONALS IN 2022 9 Security will dominate China’s 2022 political agenda ahead of the forthcoming 20th National Communist Party Congress. Ensuring Xi Jinping’s unquestioned reappointment as Party Secretary will be the Party’s utmost priority. MNCs should keep a low profile and focus on compliance with a raft of new laws and regulations, including the Data Security Law and the Personal Information Protection Law, which aim to protect citizens and bring stability to markets. Equally, MNCs should not make bold or dramatic moves ahead of the Party Congress and should not anticipate significant new policies related to opening and deregulation in 2022. In strategically important sectors, government industrial policy will support and offer subsidies to domestic champions. MNCs must audit themselves to avoid crosscutting national security hotspots—whether political, ideological, economic or technological. SECURITY & DATA: DRIVING FORCES BEHIND POLICYMAKING Ongoing geopolitical tensions and the upcoming 20th National Communist Party Congress make 2022 a critical year for China. This period of acute political sensitivity is cementing a risk-averse mindset within government to mitigate economic instability. From addressing the risk of food and resource shortages to ensuring control over strategic sectors, all policy decisions will have strategic significance in 2022. Within this environment, MNCs should exercise extreme caution when deciding how to handle sensitive matters that could intersect with China’s long-term interests. MNCs must prepare for a greater emphasis on cybersecurity and data issues in 2022. Enforcing the privacy-oriented Personal Information Protection Law (PIPL) and the national security-oriented Data Security Law (DSL) is already underway. If not already completed, MNCs should compare their compliance with the EU GDPR in developing mechanisms to adhere to the PIPL. MNCs operating in sensitive areas, including e-commerce, healthcare and automotive sectors, should anticipate increased government scrutiny under the DSL. MNCs should mind China’s long-term focus on “technology self-reliance”—a central pillar of China’s national security strategy. Increasing state support for domestic competitors is an irreversible trend; MNCs hoping to grow in China will need to demonstrate how they support China’s global competitiveness.
  • 10. CHINA SIGNPOSTS: A PRACTICAL GUIDE FOR MULTINATIONALS IN 2022 10 Chinese economic and industrial policies reinforce the need for self-reliance, but Dual Circulation still requires MNC innovation, expertise and export markets. Building more resilient corporate structures should be a priority for 2022. This will include reviewing local partnerships, investments, procurement relationships and product development arrangements. Such a review should help accelerate China market growth, insulate global and local operations against geopolitical risks and protect against other external shocks. Businesses that double down on their commitments to China, while creating strategic separation from their parent entities, will be most resilient and best placed for growth. DUAL CIRCULATION: UPGRADING “IN CHINA, FOR CHINA” One of Beijing’s responses to geopolitical friction is to take actions that make China less dependent on the world, but make the world more dependent on China. This “Dual Circulation” strategy seeks to insulate China from the unstable ebbs and flows of the global economy and place its own economic destiny firmly in its own hands. This strategy seeks to elevate the Chinese consumer to become the bedrock of its economy, empowering domestic companies and enhancing local supply chain resilience. Beijing also wants to reduce dependence on export markets and limit the impact of U.S. and foreign government actions to stymie access to the critical technologies essential to China’s development. While this undoubtedly means greater support for domestic entities, especially Chinese companies in critical sectors, this does not mean foreign companies are unwelcome in China. Instead, Beijing wants foreign businesses to occupy specific roles within the market and contribute to “Dual Circulation.” Regardless of past experience, MNCs need a thorough rethink of what it means to be “in China, for China.” Treating China as a “client” for products or a “source” for global markets is no longer enough. Those with market access are increasingly expected to demonstrate how their presence empowers domestic innovation, strengthens domestic supply chains and adheres to social and political priorities. This can be done through value chain partnerships, investments or localizing R&D to develop products for global markets, or “in China for the world.” This will have profound implications for the structure of MNCs. While some are localizing data to ensure compliance and build trust, others already treat China as a second home market—complete with parallel operations and a full value chain. Creating this firewall may protect MNCs from geopolitical turbulence and contradictory orders issued by different national governments.
  • 11. CHINA SIGNPOSTS: A PRACTICAL GUIDE FOR MULTINATIONALS IN 2022 11 China’s growing middle class is demanding higher quality products and services and pushing back against systemic economic injustices. MNCs that employ and serve the needs of underdeveloped regions and underserved populations in China are uniquely poised to secure new opportunities. Common prosperity is consistent with decades of Party doctrine and articulates an expectation that all companies—foreign and domestic—increase their commitments to give back to society and encourage CSR, philanthropy and stakeholder capitalism. MNCs should look for areas of alignment and intersection with the Common Prosperity agenda, a set of long-term goals which aim to address China’s socioeconomic inequality and establish a more sustainable socialist development model. COMMON PROSPERITY: EXPANDING THE PIE While Common Prosperity has been framed as a new initiative, it is merely a new label for a set of long-term goals. It is closely aligned with the Chinese government’s other long-standing priorities, such as transitioning from high quantity to high-quality growth, expanding the middle class through poverty alleviation and rural revitalization and promoting social and economic fairness. Despite misconceptions, Common Prosperity does not discourage businesses and individuals from getting rich. Instead, the government expects the wealthy to inspire and play a greater role in supporting marginalized groups through corporate social responsibility and philanthropic efforts. The government will adopt a wide range of measures to achieve Common Prosperity. In the short-term, businesses should expect the introduction of new regulations and increased scrutiny in certain sectors—such as technology, real estate and education— to ensure more fair market practices and equal market access for all. In the medium and long-term, central and local authorities will focus initiatives on ensuring access to basic social welfare such as education and healthcare for low-income groups, particularly in rural and underdeveloped areas. The government is also toying with tax reform—including piloting property tax schemes in certain areas—to facilitate a more equal income distribution. The government may also increase personal income and consumption taxes that will mainly affect high-income groups.
  • 12. CHINA SIGNPOSTS: A PRACTICAL GUIDE FOR MULTINATIONALS IN 2022 12 Domestic reforms to promote China’s economic stability will create short-term volatility for businesses. MNCs with Chinese partners or investments in the internet sector, real estate and other high-risk industries should be alert to potential regulatory spillover into their operations. MNCs can continue to find opportunities in critical sectors where China still requires global expertise and knowledge—particularly in financial services, advanced manufacturing and technology. Beijing’s efforts to mitigate near-term financial risks present an opportunity for foreign MNCs, particularly if they can align with the Party’s long sought economic restructuring. REGULATORY REFORM: REMOVING BARRIERS TO ACHIEVE ECONOMIC REBALANCING The focus on maintaining Chinese economic stability means regulatory decisions will be highly surgical in 2022. As a result, measures will focus on stabilizing the real economy while also creating a more robust economy needed in the long-term. MNCs should therefore expect a two-pronged approach: a regulatory tightening in areas considered as “social ills,” and a targeted opening-up in sectors in need of a structural economic shift. The government’s scrutiny of monopolistic behavior, especially surrounding data and algorithms, will continue at pace. Reforms are likely to continue in China’s financial and capital markets. In light of China’s latest property sector crisis, Beijing faces immense pressure to contain systematic financial risk by curbing debt and excessively risky offshore investments, and targeting illicit cross-border transactions. The need to improve the efficiency of the Chinese financial sector is also pushing Beijing to look outward. Officials seek trusted players that can provide the jolt (and capital) required to not only establish a well-functioning financial system, but also underwrite the critical industries needed for its long-term development goals. Foreign financial institutions may find significant opportunities to deepen their participation in China. These opportunities, however, may also present new risks for MNCs, such as a potential “spillover effect” of a Chinese regulatory crackdown for foreign firms.
  • 13. CHINA SIGNPOSTS: A PRACTICAL GUIDE FOR MULTINATIONALS IN 2022 13 Trade is an increasingly important tool in the geopolitical toolboxes of Western countries as they address allegations against China’s human rights practices. Beijing will also use coercive economic measures in response to foreign actions on issues it views as key to China’s sovereignty. Western countries will not subordinate human rights allegations in China to economic or trade interests. While the Beijing Winter Olympics will be a flashpoint, policymaking in this area will continue throughout 2022. MNCs will increasingly be expected to have visibility into their entire supply chain. All companies should already be focused on auditing, diversifying and de-risking. As MNCs navigate the consequences of geopolitical and trade issues, home nation governments and the Chinese government will both increasingly expect extraterritorial compliance—for companies to uphold their own country’s values in every jurisdiction where they operate. TRADE & SUPPLY CHAINS: CAUGHT IN THE CROSSFIRE China’s bids for bilateral trade agreements have stalled. Two years after the U.S.-China Phase I Agreement, bilateral trade relations remain poor as China has failed to meet purchasing commitments and the Biden administration maintained or upgraded several Trump-era enforcement actions. Just one year after the EU-China Comprehensive Agreement on Investment (CAI), ratification is on ice aafter China implemented sanctions against EU officials due to their stance on Xinjiang. Chinese coercive economic measures against smaller EU states over Taiwan further complicate its resuscitation in 2022. As brute force proves less effective in shaping international affairs, countries are increasingly defaulting to wielding their markets and economic influence to encourage strategic rivals to change their behavior. MNCs will continue to face greater compliance requirements as trade policy and domestic agendas align on human rights. In Washington, the new Uyghur Forced Labor Prevention Act entering into force in mid-2022 will require companies to prove imports from Xinjiang are free from forced labor. While the EU Commission may have postponed the release of its proposed human rights and environmental due diligence directive, some EU member states, such as Germany and the Netherlands, are forging ahead with mandatory due diligence requirements of their own. Chinese officials will likely balance projections of domestic strength with economic stability. MNCs need to watch for Chinese countermeasures deployed in response to Western government actions on human rights. As these may single out specific industries or companies, headquarters should be in lockstep with in-country leadership to ensure alignment. Establishing and maintaining good working relationships with local officials and regulators where companies have a significant presence is more essential than ever.
  • 14. CHINA SIGNPOSTS: A PRACTICAL GUIDE FOR MULTINATIONALS IN 2022 14 The political significance of this year for the Party lowers the chance that COVID-19 restrictions will be completely lifted in 2022. Headquarters will need to rely more than ever on their in- country presence or local partnerships to run their businesses and supply chains. Maintaining trust and managing through the opacity caused by the physical and information divide will become increasingly essential for business and supply chain continuity. Border restrictions and other COVID measures will frustrate MNCs that operate inside and outside of China, demanding new strategies for coordination between headquarters and local management. COVID-19: SMALL GLIMMERS OF HOPE With the Winter Olympics and the 20th National Communist Party Congress taking place in Beijing this year, China is very likely to maintain its zero-COVID-19 policy and impose local lockdowns whenever needed. This zero-tolerance strategy may chafe against the government’s urgent need to reverse slowing economic growth caused by sudden restrictions. The sole silver lining is in manufacturing, where government efforts to preserve economic growth will result in minimizing disruptions to production as much as possible. In-person engagement with government officials will only be possible for those based in China. MNCs with a strong in-country presence should take advantage of this, empowering local teams to make their presence felt and commitment to China known. Those lacking boots on the ground will need to maintain and refresh alternative strategies and intermediaries, whether finding a reliable partner or investing in relationships virtually where possible. The ability to move staff in and out of China will remain severely limited in 2022, meaning the ability of MNCs to execute mission-critical business decisions may be delayed. In the absence of details on an upgraded fast track for U.S.-China business travelers and continued uncertainty in China on the Omicron variant, companies will be challenged to strengthen their communication channels to minimize the widening information gaps between China and headquarters. This will prove critical in responding quickly to emergency situations, such as the impact of localized lockdowns, to maintain business continuity and ensure employee well-being.
  • 15. CHINA SIGNPOSTS: A PRACTICAL GUIDE FOR MULTINATIONALS IN 2022 15 Heightened environmental compliance pressures and regulatory change require MNCs to closely monitor policies and trends to enable well-informed business decisions. Companies should anticipate and proactively adapt to forthcoming changes to minimize business disruption. Green development creates business transformation and reputation-building opportunities for MNCs who can bring innovative technical solutions and practices to China. Businesses need to assess the resilience of their long-term sustainability plans, stay ahead of a raft of new compliance requirements and seize opportunities which align with Beijing’s climate and environmental objectives. ENVIRONMENT & ENERGY: STARTING THE LONG MARCH TOWARDS DECARBONIZATION President Xi Jinping’s announcement of China’s decarbonization goals casts a long shadow over future environmental policymaking. The emergence of a long- term national framework to oversee decarbonization in the coming decades is instructive of China’s ambitious time- lines, and is already being matched by a wave of supportive policies at the central and local levels. In some parts of Eastern China and areas surrounding Beijing, pollution standards are now higher than similar regulations in Western Europe and North America. While resource constraints caused by global shortages and the transition away from coal may temporarily relax some emissions standards in 2022, the overall trend will move towards stricter standards in the near future. MNCs will need to consider whether their transition plans are future proof to withstand long-term compliance rather than piecemeal investments to meet current standards. China’s sustainable transition also creates opportunities for foreign companies to improve their sustainability performance in China and demonstrate value. Techno- logical innovation will be essential to minimizing the economic impact of this transition and achieving China’s long-term environmental objectives. While the government will likely turn to stimulus to incentivize the green transition, a lack of domestic expertise remains a major barrier. MNCs with a strong sustainability commitment are well positioned to introduce global standards and advanced practices in key areas, such as supply chain management, sustainable consumption, renewable energy, green infrastructure and smart transportation. These contributions can demonstrate commitment to development goals and provide a platform to institutionalize engagement with key stakeholders and industry partners.
  • 16. CHINA SIGNPOSTS: A PRACTICAL GUIDE FOR MULTINATIONALS IN 2022 16 ABOUT APCO WORLDWIDE APCO’S GLOBAL CHINA PRACTICE CONTACTS CONTRIBUTORS James Robinson Global Lead, Geo-Commerce, New York jrobinson@apcoworldwide.com Teresa Lu Managing Director, Global China Practice, Washington D.C. tlu@apcoworldwide.com Anne Wang Chief Operating Officer, Greater China qwang@apcoworldwide.com Bruce Fu Managing Director, Beijing bfu@apcoworldwide.com Jeff Astle Managing Director, Shanghai jastle@apcoworldwide.com Anthony Marchese (London) Yining Yuan (Beijing) Lucas Browne (New York) Ryan Morgan (Washington D.C.) Shuang Shan (Beijing) Vivian Zhu (Washington D.C.) Nina Zholudeva (Shanghai) Freda Zhang (New York) Rosalind Reischer (Washington D.C.) Justin Iannacone (Washington D.C.) Aileen Kearney (London) Alistair Burlinson (Shanghai) Jane Zhuang (Shanghai) APCO Worldwide is an advisory and advocacy communications consultancy. We partner with public and private sector organizations to help them catalyze progress, act with agility and build reputations, relationships and solutions that enable success. APCO is an independent and majority women-owned business. APCO’s Global China Team advises leaders on their China market strategies and supports leading Chinese enterprises as they expand globally. The team includes consultants throughout Europe, the United States and Asia and is part of APCO’s trailblazing Geo-Commerce offering, which guides clients whose interests intersect geopolitics and commerce. The Global China Practice complements APCO’s strong onshore business in China, which boasts more than 25 years of experience supporting multinational clients on the ground in China from offices in Beijing, Shanghai and Hong Kong.