ON24 anti-bribery & anti-corruption policy

1. Policy statement

ON24 is committed to conducting business in an ethical and honest manner and implementing and enforcing policies and procedures to prevent bribery and corruption. We take a zero-tolerance approach towards bribery and corrupt activities, and we are committed to conducting all our business dealings and relationships professionally, fairly, and honesty.

As outlined in our Code of Business Conduct & Ethics, ON24 conducts business with the highest level of integrity. This policy sets forth a global minimum standard for complying with all laws relating to anti-bribery and anti-corruption in  the jurisdictions in which we operate, including the U.S. Foreign Corrupt Practices Act of 1977 and the UK Bribery Act of 2010. All directors, officers, and employees, whether temporary or permanent, full-time or part-time, agents, partners, and other third-party representatives of ON24 (collectively “Personnel”) are responsible for the prevention, detection, and reporting of bribery in any part of our business or supply chain.

2. Definitions

A “bribe” refers to an inducement, reward, or anything of value offered to another individual in order to gain a commercial, contractual, regulatory, or personal advantage. “Bribery” refers to offering, giving, promising, asking, agreeing, receiving, accepting or soliciting something of value to gain an advantage or to induce or influence an action or decision. This Policy prohibits bribes to anyone, whether or not the person is a government official or a private party.

Bribery is illegal – it is against the law to offer or accept a bribe. Personnel must not engage in any form of bribery, including directly, passively, or through a third party. Willfull blindness is not a defense.  For example, Personnel must not:

• Give or offer any payment, gift, entertainment or other benefit with the expectation that a business advantage will be received in return or as a reward;
• Accept an offer that they know or should have reason to know was made with an expectation that ON24 will provide a business advantage to them or someone else; or
• Threaten or retaliate against another person who has refused to offer or accept a bribe or who has raised concerns about possible bribery or corruption.

3. Unacceptable gifts, payments and contributions

Gifts and entertainment 

This policy does not prohibit Personnel from giving or accepting normal and appropriate gifts and entertainment for legitimate purposes, such as building relationships, maintaining company image or reputation, or marketing company prouducts or services, if the giving or receiving of these gifts and entertainment meets the following requirements:

• It is not made as an explicit exchange for favors or benefits;
• It is not made with the suggestion that a return favor is expected;
• It is in compliance with local law and with the policies of the receiving entity;
• It is given in the name of the company, not in an individual’s name;
• It is not given as cash or cash equivalent, such as a voucher (except when given as part of an approved promotion campaign involving chance (e.g. a random drawing));
• It is a promotional gift of low value such as pens, bags, shirts, hats, or other low value branded articles;
• It is appropriate for the circumstances (e.g. giving small gifts around holidays or as a small thank you to a company for helping with a large project upon completion);
• It is of an appropriate type and value depending on the circumstances and taking into account the reason for the gift;
• It is given/received openly, not secretly;
• It is not above a certain excessive value or unduly lavish;
• It is not offered to, or accepted from, a government official or representative or politician or political party, without the prior approval of the Head of Human Resources.

As a general guidance, Personnel should not accept more than $100 in gifts or $250 in entertainment from a single source per 12-month period. Personnel may not accept any gifts and entertainment if such receipt would interfere with the ability to carry out employment duties in an objective, honest, professional manner. If Personnel is uncertain whether something is a bribe, gift, or entertainment, or if their acceptance of a gift or entertainment would exceed the amounts discussed above, they must consult the Head of Legal prior to its acceptance by emailing compliance@on24.com.

Facilitation payments 

ON24 recognizes that facilitation payments are a form of bribery. Giving or offering a facilitation payment to a government official in any country to facilitate or speed up a routine or necessary procedure is not permitted. In addition, ON24 does not allow kickbacks to be made or accepted. We recognize that kickbacks are typically made in exchange for a business favor or advantage.

Charitable contributions 

Donating to charities, whether through services, knowledge, time, or direct financial contributions (cash or otherwise) is a great way to give back. Personnel must ensure that charitable contributions are not used to facilitate and conceal acts of bribery. All requests for sponsorship or donations must be approved by the Head of Human Resources in advance.

4. Reporting a concern

If Personnel are offered a bribe, asked to make a bribe, or suspect that any bribery, corruption or other breach of this policy is occurring in any parts of our business or supply chain, Personnel are required to immediately raise their concerns with the Head of Legal. If Personnel are uncertain about whether a certain action or behavior is considered bribery or corruption, they should speak to the Head of Legal by emailing compliance@on24.com.

ON24 will support anyone who raises a genuine, good faith concern under this policy, even if the concern turns out to be mistaken. We will not tolerate retaliation in the form of any detrimental treatment (including dismissal, disciplinary action, threats, or other unfavorable treatment) as a result of refusing to accept or offer a bribe or other corrupt activity or reporting a suspicion that bribery may be taking place in any part of ON24’s business or supply chain. If Personnel believe that they have received detrimental treatment after reporting a concern or refusing to accept or offer a bribe, they should inform the Head of Legal by emailing compliance@on24.com.

5. Recordkeeping

ON24 is required to make and keep accurate books and records and maintain an adequate system of accounting controls. Personnel must make sure that all books and records are complete, accurate, and honestly reflect business transactions, are timely and in accordance with applicable accounting rules, and consistent with internal policies. Personnel must submit all expenses relating to gifts, entertainment, or payments to third parties in accordance with the ON24 Global Travel & Expense Reimbursement Policy and record the reason for the expenditure.

6. Training & acknowledgement

All employees are required to complete annual anti-bribery and anti-corruption training and must read, understand, and comply with this Policy as a condition of employment.