I. INTRODUCTION 

At Zenlayer, we are striving to provide the best services and solutions to improve the digital user experience for every organization and person in the world. We believe that how we fulfill our mission is as important as the mission itself. Therefore, we must not only comply with all laws in the countries where we operate, but also conduct our business with the highest level of honesty, integrity, ethical conduct, and professional practices. 

This Employee Code of Conduct (“Code”) provides some guidelines for business conduct required of Zenlayer employees. Please read this Code, refer to it and let it guide your business decision-making. 

This Code should be read in conjunction with the Employee Handbook and other Zenlayer policies and procedures. 

II. SCOPE 

This Code applies to all Zenlayer International Holding Limited (together with its subsidiaries and affiliates worldwide) (“we,” “our,” “us,” “the Company”) directors, officers, and employees (“you,” “your,” “Employees”).

III. ETHICAL DECISION-MAKING

3.1 CONFLICTS OF INTEREST

Zenlayer employees are expected to use their judgment to act, at all times and in all ways, in the best interests of the Company while performing their job duties.

A conflict of interest occurs when your personal or private interest interferes, or potentially interferes, with the interest of Zenlayer. Any personal, business, financial, or employment interest that may adversely impact, conflict, or compete with the business of Zenlayer is strictly prohibited. All employees shall actively avoid any acts that may be deemed as a conflict of interest, or potential conflict of interest. Any situation that may be construed to be a conflict of interest must be avoided.

Examples of actual or potential conflicts of interest include using the resources of the Company for personal gain, using your position in the Company for personal gain, or working for a current or potential competitor, customer, or vendor in any capacity.

If you believe that you may have a conflict of interest with the Company, you must promptly disclose the potential conflict to your direct manager, HR, and Ethics and Compliance. Avoid participating in decisions that might raise the appearance of a conflict until you receive guidance from HR or Ethics and Compliance.

3.2 OUTSIDE EMPLOYMENT

Zenlayer’s goal is to offer a platform to help employees strive and do great things together. In the event an employee wishes to work or is working for other businesses during their employment with Zenlayer, the employee is prohibited from:

(i) accepting or performing work of a nature that conflicts or competes in any way with the businesses or services of Zenlayer;

(ii) unauthorized use of any Zenlayer resources including, but not limited to, confidential information and any Zenlayer-owned equipment;

(iii) performing any non-Zenlayer activities on Zenlayer premises; and

(iv) soliciting or conducting any non-Zenlayer work during paid working time.

Employees are advised to carefully consider the practical demands any additional work activity will create before accepting outside employment.

3.3 GIFTS AND HOSPITALITY

Giving or receiving gifts or hospitality to or from current or future customers or business partners can potentially create a conflict of interest. However, Zenlayer recognizes that it is customary in some situations for customers or business partners to offer gifts or hospitality to those with whom they do business to build goodwill and strengthen working relationships. Even if in situations where gifts and hospitality are customary, employees shall not solicit or accept any gifts or hospitality solely for personal benefit or to achieve an improper purpose related to Zenlayer business.

Employees cannot give anything of value to a government official to get or keep business or gain an improper advantage. Employees may provide modest gifts or hospitality to government officials where there is a legitimate purpose and the gifts or hospitality is not being provided in exchange for any action or inaction by the official. For guidance on interactions with government officials, please refer to Zenlayer’s Global Anti-Corruption Policy and Global Gifts and Hospitality Policy.

Employees are encouraged to consult with Ethics and Compliance on the appropriateness of any gifts and hospitality before taking actions.

 

IV. COMPLIANCE WITH LAWS

Zenlayer operates around the globe and respects the laws and regulations of the U.S. and all other countries where we operate. While it is impossible to list all the laws and regulations that are applicable to Zenlayer’s operations, below are some of the important legal areas to keep in mind.

4.1 ANTI-CORRUPTION/ANTI-BRIBERY

Zenlayer strictly prohibits any bribery or corrupt payments, either in commercial dealings or interactions with government officials. For any money spent, employees must keep accurate and complete financial records, submit accurate and complete financial reports, and comply with the Company’s systems of internal control. Please refer to Zenlayer’s Global Anti-Corruption Policy for details.

4.2 COMPETITION/ANTITRUST

Antitrust laws protect consumers by prohibiting anticompetitive conduct that can restrict free competition. Zenlayer is committed to competing in a fair and vigorous manner, in compliance with all applicable competition and antitrust laws. 

Zenlayer employees must never agree, either directly or indirectly, with competitors:

(i) to set any aspect of prices or terms related to our products or services;

(ii) to allocate customers, advertisers, territories, or product markets;

(iii) to boycott a customer or supplier; or

(iv) on bid levels or whether to submit a bid on any prospective business.

Employees are encouraged to consult with Ethics and Compliance if you have any questions about competition or antitrust laws.

4.3 INTERNATIONAL TRADE LAWS

U.S. and international trade laws control where Zenlayer can send or receive its products and services. Employees are required to follow all applicable trade laws when sourcing, importing, or exporting to a foreign country. Employees must not conduct business with governments, companies, or individuals if the Company would be barred from doing so. 

International trade laws are complex. Therefore, employees must consult with Legal Department whenever you are transferring products, services, equipment, or any form of technical data from one country to another.

4.4. DATA PRIVACY 

Zenlayer’s customers, business partners, and employees have entrusted their business and personal information with us. We understand the importance of keeping it safe and using it responsibly.

Zenlayer is committed to using technology ethically, respecting people’s privacy, and protecting their data. Zenlayer abides by all applicable data privacy laws and regulations. We also require our employees to follow fair information practices when dealing with customers’, business partners’ and employees’ information. Employees must:

(i) protect confidential information; 

(ii) only collect, access, process and retain information that is absolutely necessary; 

(iii) only use information for the purpose identified or agreed upon; and

(iv) deploy adequate technologies to safeguard information from unauthorized access or disclosure.

Employees are encouraged to consult with Ethics and Compliance for any questions regarding data privacy laws and fair information practices.

V. WORK ENVIRONMENT 

At Zenlayer, our goal as a community is to establish a welcoming and vibrant environment where all employees can feel safe and thrive. 

5.1 PROFESSIONAL CONDUCT 

We expect all employees to act in a professional manner whenever you are on Company property, conducting Company business, or representing the Company at business or social functions. Whether interacting internally with your team members or externally with a customer, all employees must act with common courtesy and respect as it is expected in a business forum. 

5.2 NO VIOLENCE OR THREATS 

Violence, or threats of violence, is strictly prohibited in the workplace. Any such conduct is unacceptable behavior and will be treated as a serious violation of the Company’s policies. 

5.3 NO HARASSMENT OR DISCRIMINATION 

Zenlayer expressly prohibits discrimination or harassment based on an individual’s race, color, ancestry, ethnicity, religion, sex, pregnancy, national origin, age, disability, marital status, veteran status, military status, genetic information, sexual orientation, gender identity or expression, or any other protected status.

VI. REPORTING 

Every Zenlayer employee has an affirmative obligation to report violations of this Code and other Company policies immediately to Ethics and Compliance. External stakeholders are also encouraged to discuss any concerns they may have with a relevant point of contact in Zenlayer or Ethics and Compliance. 

Reports may be submitted anonymously by using Zenlayer Ethics Portal. However, we encourage you to consider revealing your identity so that we can properly follow up with and investigate alleged violations. Zenlayer will ensure that appropriate confidentiality measures are taken. 

VII. NON-RETALIATION 

Employees can raise any legitimate concerns and make good faith reports without fear of retaliation. Zenlayer strictly prohibits any forms of retaliation against an employee who seeks advice, reports a good faith concern, or assists in an investigation or proceeding. 

Questions or Concerns

Zenlayer Ethics Portal

Ethics Helpline: (800) 461-9330 

Email: ethics@zenlayer.com 

Mail: Attention: Ethics and Compliance, 21700 Copley Dr. Suite 350, Diamond Bar,
CA 91765, United States