Preventing Bribery & Corruption
Never offer or accept bribes – especially when dealing with public officials.
AppFolio is committed to conducting business ethically and transparently. We never offer or accept payments or incentives intended to improperly influence business decisions, and we avoid behavior that can be perceived as bribery or corruption. We keep accurate and complete records of our transactions and do not allow anyone to conceal or falsify them.
All employees are responsible for complying with the rules that govern business and other dealings with governments. If you deal with governments, government employees, or public officials, you are particularly responsible for learning and complying with all rules that apply to working with government officials.
Below are some situations where you may engage with government officials and guidelines to help navigate them:
Requests by Regulatory Authorities:
- Cooperate fully with government inquiries and investigations.
- Refer all government requests for Company information or documents to the Legal Team or Compliance Team.
Gifts, Entertainment, and Meals:
- Never offer any gifts or payments to a public official or a government employee. What may be appropriate in commercial business dealings could be deemed illegal and possibly criminal when dealing with the government. See AppFolio’s Gifts, Entertainment & Meals Policy for more information on appropriate business dealings.
- AppFolio and its employees do not make contributions to for-profit businesses. Donations to charitable, non-profit 501(c)(3) organizations may be allowed on behalf of AppFolio and always require pre-approval from the AppFolio Give Back Committee. Charitable donations should never be made with any intent to win improper influence over a business decision.
Political Contributions:
- It is Company policy that we comply with all applicable laws, rules, and regulations regarding political contributions.
- You may volunteer your personal time for political activities, such as events for candidates or organizations of your choice, as long as it does not interfere with work hours and that you do not use AppFolio’s resources such as phones, company email, or equipment.
- You may not make or commit to political contributions on behalf of AppFolio.
Lobbying:
- Obtain approval from the Chief Legal Officer for any work activity that requires lobbying communication with any government official or employee of a legislative body.
Government Contracts
- Understand and comply with relevant laws and regulations that apply to government contracting.
- Engage Procurement when considering government contracts, and refer any contract with any government entity to the Compliance & Ethics Team for review and approval.
Do
- Cooperate fully with appropriate government inquiries and investigations. All such inquiries and investigations must be brought to the Legal Team or Compliance Team.
- Understand and comply with all contract terms and conditions, laws, and regulations applicable to AppFolio’s dealings with governments. Engage Procurement when considering government contracts.
Don't
- Give gifts or offers to any government official without consulting the Compliance & Ethics Team.
- Use Company assets – including taking time off of work to volunteer for a political campaign – without consulting the Compliance & Ethics Team first.
Key Takeaways
- Never offer or accept payments or incentives intended to improperly influence business.
- Ask for help. When dealing with government contracts or requests from regulatory authorities, reach out to the Compliance & Ethics Team.
- Keep accurate records of transactions. Don’t allow anyone to conceal or falsify them.
Frequently asked questions
A: Any individual who holds a position within an agency, department, or other body of any foreign, federal, regional, or municipal government, including any state-owned and state-operated enterprises.
A: Refer the request immediately to the Legal or 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: No. Accepting any gifts or forms of entertainment in return for routine business dealings is considered a bribe and prohibited.
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.