A: The Helpline is operated by a third-party compliance and ethics-related software company. The third party software company collects information from the reporting party and securely sends it to AppFolio’s Compliance & Ethics Team, who will determine the appropriate course of action to ensure the report is addressed timely and appropriately.
A: Yes. If you have an ethics or compliance question or an inquiry regarding a company policy, you can ask it anonymously and confidentially. All questions will be sent to the Compliance & Ethics Team and answered by the relevant department.
A: It’s better to raise a concern than to wait and cause potential harm to you, another employee or the company. Provide as much information as you can – remember that AppFolio will not retaliate against you for notifying it of any good-faith complaints, concerns or questions. Retaliation is in and of itself a reportable violation of AppFolio policies and the law and should be reported.
A: Good faith means you are honestly providing truthful and accurate information about the concern you are raising. It doesn’t mean you have to be right. Reports made dishonestly, maliciously or with an ulterior motive are a violation of the Code and may result in disciplinary action, including termination.
A: Coming forward with any concern is always the right thing to do. Even if a suspected violation turns out to be unsubstantiated after an investigation takes place, you will never face retaliation for coming forward.
A: As a manager, you are responsible for escalating all concerns brought to your attention by any employee – even if the employee is outside of your direct reporting line. Bring the complaint directly to HR or the Compliance & Ethics Team for guidance on next steps.
A: Reporting a problem is always better than staying quiet. Encourage teammates to come forward with their concerns, even if they’re unsure. If the complaint is unsubstantiated after an investigation is complete, reporting the concern is still the right thing to do. Remember – you or your teammates will never be retaliated against for reporting any concern in good faith.
A: Yes. This Policy applies to all employees in the physical workplace and outside of it when performing their employment duties for AppFolio. It also applies at company-sponsored events, including off-sites, celebrations and other gatherings.
A: Employees may engage in moderate consumption of alcohol served at company social or business events. Everyone involved must exercise good judgment, act professionally and responsibly and follow guidelines for attending the event.
A: An “illegal drug” is any drug that is not legally obtainable, or that is not being used as intended. This includes prescription drugs not being used in prescribed amounts, for prescribed purposes or not being used by the person to whom it is prescribed.
A: Yes. You should inform your manager and submit a disclosure with the Compliance & Ethics Team to review the position, the organization and what it does, and if it might have any impact on your responsibilities at AppFolio.
A: As long as you are not making the hiring decision and your sister will not be reporting to you, you can recommend her to HR, who may put her through the standard application process. Be sure to disclose the relationship to HR and the Compliance & Ethics Team before making the recommendation.
A: No. Communicating with representatives from expert networks creates real risk for AppFolio and for you individually. Even if the contact says you won’t be asked about AppFolio’s confidential or proprietary information, you may find yourself in a situation where these types of questions come up. Further, you have no idea how the information you provide is going to be used. Avoid speaking to expert networks whenever possible. To the extent that you are engaged by one, please report this to the Compliance & Ethics Team.
A: No. It’s likely that information has not been made public yet, which means it is material nonpublic information. Tipping off your brother with this information to help his financial decision-making is illegal and could result in serious penalties.
A: No. Do not engage with companies looking to obtain confidential information about AppFolio, its customers, or its partners. If you have been contacted by a company seeking information, contact the Legal & Compliance Team for guidance.
A: Business offers can include gifts, entertainment, meals, services, reimbursements, hospitality, favors, privileges, or any other items of value. If you’re unsure if something is a “gift” contact the Compliance & Ethics Team.
A: Yes. Company swag or gifts that are nominal in value, moderately priced, and appropriate for the event/occasion are generally okay. All gifts must be disclosed to the Compliance & Ethics Team before they are given.
A: No. Even if the tickets are reasonably priced, attending the event will not provide a legitimate business purpose or an opportunity to advance AppFolio’s relationship with the vendor since the vendor will not be present.
A: Yes! Generally, company-sponsored events can be great opportunities to strengthen business relationships. However, if the guest is a government official, email the Compliance & Ethics Team before proceeding.
A: No. Personal purchases should never be made on company cards. Reimbursements from AppFolio to employees can only be made for legitimate business-related expenses and this must be reflected accurately in our records.
A: You should never be pressured to act in a way that goes against our code or standards. This could be a misrepresentation of our financial condition and can result in fraudulent records. Managers have an increased responsibility to demonstrate ethical behavior. If you believe that your manager is violating our standards, report it to the Compliance & Ethics team.
A: Use caution when seeking information from current customers. Avoid questions that may appear to solicit competitor information. All employees, especially sales representatives, should never make false or misleading representations about new AppFolio products to new or existing customers. This can impact revenue recognition. If you have questions on what you can and can’t ask current or prospective customers, contact Legal & Compliance.
A: If you plan to talk to a competitor, disclose that you are an AppFolio employee and avoid having conversations about business that may lead to obtaining or disclosing confidential company information. Stick to discussing only public information. If you find yourself in this situation and have additional questions, reach out to your manager or ask a question through the Helpline.
A: No. You should end this conversation and contact the Legal & Compliance Team. Having a conversation about upcoming products with a competitor can give the appearance of impropriety. A general discussion about your job may be okay, but avoid discussing specific business topics like products or pricing.
A: Suspicious activity can appear in many different forms. You should understand how certain activities can impact AppFolio, how to identify red flags and where to report them. Escalate concerns to your manager or to AppFolio’s Anti-Money Laundering (AML) Compliance Officer. Remember – even if you are unsure, it’s always best to raise concerns.
A: Refer the request immediately to the Legal & Compliance Team who will work with your team to ensure the appropriate information is disclosed – and avoid the unintentional or inappropriate disclosure of any nonpublic information.
A: No. Any payment made to a government official to facilitate a transaction (“facilitation payment”) is considered a bribe and can result in serious consequences. If a government employee makes you an offer in return for a favor, report it immediately to the Compliance & Ethics Team.
A: The Foreign Corrupt Practices Act makes it illegal to offer, pay, promise to pay, or authorize to pay any money, gift, or item of value to any foreign official, political party, or candidate to assist the company or another to obtain or retain business. Currently, AppFolio’s business does not require frequent interactions with foreign government officials, but if you have questions, ask the Compliance & Ethics Team.
A: You are not expected to know every applicable law and regulation. If your job requires the exchanging of technology, information, or the exportation or importation of goods, you should have a general understanding of the sanctions laws mentioned above. If you are unsure, the Compliance & Ethics Team is available to help answer any questions you may have.
A: Use your best judgment. Any information about our company and our customers that the general public doesn't have knowledge of or access to is likely confidential. If you are unsure if the information you’re dealing with is proprietary and/or confidential, review AppFolio’s Data Classification Policy, or reach out to the Information Security Team and/or the Compliance & Ethics Team for guidance.
A: Disclosing AppFolio’s or its customers’ confidential information can result in harm to AppFolio and, potentially, risk for you (through violations of insider trading laws, creation of conflicts of interest and more). Carefully consider any communication you make via any channel and, if in doubt, reach out to the Compliance & Ethics Team.
A: Work responsibilities should be completed from an AppFolio managed (“work”) device, such as a company-issued laptop, when possible. Certain applications, such as communication and video call platforms, may be accessed on personal devices unless you are handling sensitive customer data. Never connect to any AppFolio system that houses customer data from a personal device and never download customer data to personal devices. Refer to AppFolio’s Device Policy and BYOD Policy within the Employee Handbook for more information.
A: You may use the company’s internal communication systems to raise awareness about certain charitable causes. However, using company communication systems as a means to fundraise or support political activities, such as events for politicians or political campaigns, is never allowed. If you’re unsure if the communication method you are using to raise awareness about a cause is appropriate, contact Compliance & Ethics or The Communications team. Review these tips for using internal Communications systems.
A: Like all vendors and third parties, your friend’s company will be required to undergo AppFolio’s vendor due diligence process. Once the business need for the service has been established, it is important to review other suppliers considered for the job to ensure fair competition. The vendor will also be required to undergo standard screening procedures. The ultimate decision of who to select should be made by all key stakeholders. If your friend’s company is chosen, another employee should be responsible for managing the relationship, to avoid potential conflicts of interest (or the appearance of a conflict of interest).