Zenlayer International Holding Limited Global Anti-Corruption Policy

Version 1.1 Adopted August 2021


Zenlayer International Holding Limited (together with its subsidiaries and affiliates worldwide, collectively the “Company”) has implemented this Global Anti-Corruption Policy (the “Policy”) for the purpose of ensuring compliance with the U.S. Foreign Corrupt Practices Act of 1977, as amended (the “FCPA”), the U.S. Travel Act, the U.S. Domestic Bribery Statute, the U.K. Bribery Act 2010, P.R.C. Anti-Unfair Competition Law and all other anti-corruption laws and regulations applicable to the Company’s business worldwide. 

This Policy prohibits making or receiving corrupt payments in all circumstances, whether in dealings with government officials or individuals in the private sector.



(i) any officer or employee of a government;

(ii) any officer or employee of a public international organization;

(iii) a member of a political party;

(iv) a candidate for political office;

(v) any official or employee of a state-owned business enterprise;

(vi) any private business entity;

(vii) any director, officer, employee, and agent of a private business entity.

As adopted in this Policy, following terms have specific meanings defined below.

“Person” includes, but is not limited to:

(i) influencing any act or decision of the recipient in his/her official capacity;

(ii) inducing the recipient to do or omit to do any act in violation of his/her lawful duty;

(iii) inducing the recipient to influence any act or decision of a government or

instrumentality of a government; or

(iv) securing any improper advantage.


This policy applies to all Company directors, officers, and employees worldwide (collectively “Employees”).

In addition, we expect our agents, representatives, consultants, advisors, lobbyists, brokers, and all other third-party intermediaries who interact with persons on the Company’s behalf (collectively “TPIs”) to comply with this Policy.



Employees and TPIs are strictly prohibited from promising, offering, providing, or authorizing cash payments or anything of value directly or indirectly to any person to achieve an improper purpose related to the Company’s business.

Employees and TPIs are strictly prohibited from requesting, agreeing to receive, or accepting money or anything of value from any person to achieve an improper purpose related to the Company’s business.

Employees and TPIs must make and keep accurate and detailed books, records, and accounts to reflect transactions and dispositions of the Company’s assets. Employees must comply with Company’s internal accounting controls.

Even if the Company’s competitors engage in improper behavior or corruption is an accepted practice in a region where the Company operates, employees are required to adhere to both the spirit and the letter of this Policy.



Violating anti-corruption laws may subject the Company and you to substantial fines and/or imprisonment. In addition, the Company may suffer reputational damages, suspension or debarment from government contracts, loss of export privileges and other consequences. These results can be devastating to our business. 

Any violation of this Policy will result in appropriate disciplinary action(s), up to and including termination of employment for employees. In the case of a third-party, the Company may terminate its business relations. The Company reserves the right to refer the matter to relevant law enforcement authorities.



Every Company employee has an affirmative obligation to report violations of this Policy immediately to Ethics and Compliance. Employee must also notify Ethics and Compliance of any corrupt, improper, illegal, or unusual requests for payments or benefits made by customers, TPIs, suppliers, vendors, business partners, government officials, or Company employees.

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. The Company will ensure that appropriate confidentiality measures are taken.



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



All designated employees must undergo anti-corruption trainings provided by the Company. The nature, content, and frequency of the training will be determined by the Company based on employees’ risk profile.

All designated employees are required to sign the certificate in Attachment 1 after reading this Policy. The Company may require employees to re-certify compliance with this Policy on a periodic basis.



This Policy does not create an express or implied contract of employment or any other contractual commitment. The Company may modify this Policy at its sole discretion without notice, at any time, consistent with applicable law.

This Policy should be read in conjunction with the Company’s Code of Conduct, Employee Handbook, and other policies and procedures.


Reporting Violations or Solicitations

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




I, _________________________ hereby certify that I have read and fully understood the contents and obligations under the ZENLAYER INTERNATIONAL HOLDING LIMITED GLOBAL ANTICORRUPTION POLICY (the “Policy”). I further certify that I am in full compliance with the Policy and will abide by the Policy.


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