Gifts, Entertainment & Meals
Never give or receive inappropriate gifts or entertainment.
Exchanging gifts or offering meals or entertainment in moderation can be a standard practice of doing business. But sometimes even a well-intentioned gift or offer can cross the line. Any gift that is lavish, excessive, or lacks a legitimate business purpose, especially those exchanged with government officials, can give the wrong idea and may be viewed as a bribe. Although a gift or entertainment offering may be well-intentioned, it may cause the recipient to feel influenced or obligated to do something in return.
To help you make good decisions, review these basic rules and the Gifts, Entertainment & Meals Policy before giving or receiving gifts. If you’re still unsure, ask the Compliance & Ethics Team.
No gift or business entertainment should be offered or received unless it:
- Has a legitimate business purpose and is appropriate for the circumstance
- Is permitted by law and the policies of both the giver and receiver
- Is accurately recorded in AppFolio’s books and records (if the gift is purchased using Company funds)
- Is open and transparent. You must disclose it to your manager or the Compliance & Ethics Team before giving or accepting any gift
Any gift that compromises your ability to make objective business decisions in AppFolio’s best interests is always inappropriate. Never seek to gain an advantage by making or accepting business offers that may be lavish or excessive.
Do
- Always use your best judgment.
- Keep accurate records of any hospitality or amenities that you provide or accept and submit timely receipts for reimbursement.
- Obtain approval from your manager or the Compliance & Ethics Team before giving or receiving any gift.
- Give and receive moderate gifts like Company swag to build relationships.
Don't
- Accept any offer given to influence a decision or that may appear to influence a decision. Even if a gift seems reasonable, it may create the perception that the gift is inappropriate.
- Exchange lavish gifts, cash or cash equivalents (such as gift cards), loans or stock.
- Exchange gifts with government officials without asking the Compliance & Ethics Team.
Key Takeaways
- Never use gifts where they are being used to influence a decision. These types of gifts are always inappropriate.
- Be transparent. Disclose gifts to your manager or the Compliance & Ethics Team before exchanging them.
- Exchange gifts with legitimate business purposes. Exchange moderate gifts (like Company swag or non-extravagant entertainment) to help build relationships.
Frequently asked questions
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: Gifts that are moderate in value are generally acceptable, as long as nothing is expected in return. If you are unsure if a gift you receive is acceptable, contact the Compliance & Ethics Team or submit a disclosure.