Introduction

At Zenlayer Group, 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 not only comply with 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 Ethics and Compliance Code of Conduct (“Code”) summarizes the matters that each company, director, executive officer and employee (together “Employee”, “Employees”, “you”, “your”) of Zenlayer Group (“we”, “our”, “us”, “Zenlayer”, “the Company”) should keep in mind on a daily basis. Please read this Code carefully, 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. 

  

1. Upholding Human Rights and Labor Standards

Prohibition of Forced or Child Labor: We forbid all forms of forced, bonded, or child labor in our operations and among our suppliers.

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.

Health, Safety & Wellbeing: We implement workplace safety policies, hazard assessments, and wellness programs to foster a healthy workforce.

Grievance Mechanisms: We provide multiple, confidential channels for Employees and suppliers to report human‑rights or labor concerns, protecting whistleblowers from retaliation.

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.

2. Anti-Bribery and Anti‑Corruption

Anti‑Bribery: Aligned with the U.S. FCPA, UK Bribery Act, and Zenlayer’s anti‑bribery rules, we prohibit any offer or receipt of bribes or kickbacks to secure business advantages. 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. 

Gifts & 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 are not being provided in exchange for any action or inaction by the official.

3. Ensuring Ethical Business Practices

We are committed to ethical, fair, honest business activities.

Conflict of Interest: 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 Company business 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 should be avoided. 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.

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.

Asset Management: All Company assets such as inventories and fixed assets must be controlled, used and maintained for business purposes only. We do not use them for personal gain or the benefit of others. Employees must all keep Zenlayer assets safe from loss, theft, damage, and inappropriate use.

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 must seek the prior written approval of the Company. And in all events, the Employee must ensure that no conflict of interest exists or will exist before accepting outside employment.

4. Maintaining Fair Competition and Market Integrity

We compete on merit, never through collusion or market manipulation.

Antitrust Compliance: We prohibit price‑fixing, bid‑rigging, market allocation, and other cartel behaviors, in accordance with global competition laws.

Competitive Intelligence: We gather market data only from lawful, public sources, avoiding illicit or deceptive methods to obtain competitor information.

Fair Dealing: We engage suppliers and customers on clear, non‑discriminatory terms, refusing to exploit market power to impose unfair concessions.

5. Protecting Privacy and Information Security

Guarding data is at the heart of our service promise.

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. 

Data Classification & Handling: We classify data by sensitivity and apply least‑privilege access, encryption at rest and in transit, and other ISO 27001 controls to protect confidentiality, integrity, and availability.

Incident Response: We maintain a breach‑response plan to deal with any data breach or data incidents according to applicable laws and regulations.

Data and Intellectual Property Protection: Proprietary data and information and intellectual property rights are the Company’s core assets. Protecting these assets is a crucial responsibility of every Employee. Employees must take appropriate security precautions and comply with Zenlayer’s policies and procedures for their protection. Employees should contact the Legal and Compliance Department for any questions regarding intellectual property rights or proprietary data and information. Employees may not disclose confidential information to any third party without authorization, and must follow Zenlayer’s external data disclosure rules when it is necessary to disclose confidential information involving, belonging to, or held in trust by Zenlayer.

6. Compliance with Export Controls, Sanctions, and Customs

As a multi-national organization, Zenlayer must abide by applicable laws and regulations and comply with appropriate import and export procedures and trade controls when purchasing, exporting or importing products, machines, and materials, or when sharing our technology overseas, to avoid violation of regulatory sanctions.

Sanctions Screening: We screen transactions against various sanctions lists to ensure that we do not deal with prohibited parties or bad actors.

Customs Compliance: Zenlayer has established a customs compliance system with policies and procedures aimed at global compliance, and promotes the implementation and enforcement of these policies and procedures in applicable business areas. Employees are required to make active efforts to adhere to global customs compliance and strictly implement the Company’s customs compliance policies and procedures. Employees who fail to comply with applicable customs regulations will face disciplinary actions, including termination. We engage qualified suppliers, and require those suppliers to conduct customs and logistics services in accordance with applicable laws and regulations.

Consulting with the Compliance Team: Questions about compliance with trade laws should be directed to the Legal and Compliance Department. If you are unsure about whether a business activity is compliant with applicable laws, you should speak with the Legal and Compliance Department.

Training & Certification: We require mandatory export‑control training for Employees in affected roles and conduct periodic courses.

7. Managing Environmental and Sustainability Responsibilities

As a cloud provider, we minimize our environmental footprint and drive sustainable practices internally and across our supply chain.

Environmental Management Systems: We encourage adoption of ISO 14001 systems to identify and mitigate environmental impacts—covering energy, water use, waste, and emissions to our suppliers.

Energy & Emissions: We set targets for renewable energy sourcing and continual greenhouse‑gas reductions in data centers and network operations.

E‑Waste & Resource Recovery: We follow best practices for electronic waste recycling and promote circular‑economy principles for hardware lifecycle management.

8. Reporting

The Zenlayer Group encourages Employees, suppliers, customers, and business partners to report any concerns they may have regarding any non-compliant or potentially fraudulent activities.

Reporting: Every Employee has an affirmative obligation to report violations of this Code and other Company policies immediately to the Compliance Officer.

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

Ethics Helpline: +1 (888) 414-3305 

Email: ethics@zenlayer.com legal@zenlayer.com

Mail: 21700 Copley Dr. Suite 350, Diamond Bar, CA 91765, United States

Whistleblower Protections: We maintain a global, confidential hotline and web portal—ensuring anonymity where permitted and strict non‑retaliation for good‑faith reporting.

9. Training, and Continuous Improvement

Embedding these principles requires ongoing education and process refinement.

Mandatory Training: All Employees shall complete annual training on the Code.

Policy Reviews: We review and update the Code annually (or as required by law or business changes), communicating revisions through Company channels.