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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 & Compliance team.

 

Gift, entertainment & 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. 

 

Political contributions:

  • AppFolio may communicate its position on important issues to elected representatives, government officials, and political organizations. 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 or use AppFolio’s resources such as phones, company email, or equipment.

 

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.  

  • 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. 

  • Understand and comply with all contract terms and conditions, laws, and regulations applicable to AppFolio’s dealings with governments.

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.

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.

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    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.

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    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.

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    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.

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    Key Takeaways

    1. Never offer or accept payments or incentives intended to improperly influence business. 

    2. Ask for help. When dealing with government contracts or requests from regulatory authorities, reach out to the Compliance & Ethics Team.  

    3. Keep accurate records of transactions. Don’t allow anyone to conceal or falsify them. 

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