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 honestly.
As outlined in our Code of Business Conduct & Ethics, ON24 conducts business with the highest level of integrity. This Anti-Bribery & Anti-Corruption Policy (“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, contractors, and other third-party representatives of ON24 (collectively “you”) are responsible for the prevention, detection, and reporting of bribery in any part of our business or supply chain.
2. PROHIBITION AGAINST BRIBERY
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. Willful blindness is not a defense.
You must not engage in any form of bribery, including directly, passively, or through a third party. This prohibition on bribery applies to giving anything of value, not only money. This includes providing business opportunities, jobs, favorable contracts, donations, travel, gifts, and hospitality.
You must not:
- Give, promise, offer, or authorize payment of anything of value to obtain or keep business or to secure some other improper advantage for ON24;
- Give anything of value to influence a government official’s actions;
- Solicit or accept a bribe or kickback of any kind;
- Ask or permit a partner or any third-party to take actions that this policy prohibits you from taking directly; 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.
The following situations often have a higher risk for bribery and include additional guidance:
- Transactions Must Be Transparent: Transactions that are transparent reduce the risk of a bribe or kickback. Make sure that contracts accurately reflect the economics of the agreement. Unusual arrangements such as side agreements and prepayments may be used to coverup improper payments.
- Gifts and Hospitality Must Be Reasonable: This policy does not prohibit the giving or accepting of normal and appropriate gifts or hospitality for legitimate purposes, such as building relationships, maintaining company image or reputation, or marketing company products or services. Before offering gifts or hospitality you must ensure they are not bribes or kickbacks and that there is a legitimate business purpose. You may not accept any gifts or hospitality if such receipt would interfere with your ability to carry out employment duties in an objective, honest, and professional manner. If you are uncertain whether something is a bribe, gift, or hospitality, you must consult the Head of Legal prior to acceptance by emailing compliance@on24.com.
- Charitable Donations and Sponsorships: Donating to charities, whether through services, knowledge, time, or direct financial contributions (cash or otherwise) is a great way to give back. You must ensure that charitable contributions are not used to facilitate and conceal acts of bribery. All requests for charitable donations or sponsorships must be approved by the Head of Human Resources in advance.
- Do Not Make Facilitation Payments: ON24 does not allow facilitation payments. We recognize that facilitation payments to government officials in order to secure or expedite routine administrative processes (like getting a permit) are a form of bribery. 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.
- Political Contributions: You should not make or promise any political or campaign contributions, including in-kind contributions, on behalf of, or as a representative of ON24. You may not make any political contributions intended to influence corruptly any ON24 business relationship or contract award. All requests for political contributions made on behalf of, or as a representative of, ON24 must be approved by the Head of Human Resources in advance.
4. REPORTING A CONCERN
If you 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, you are required to immediately raise your concerns with the Head of Legal. If you are uncertain about whether a certain action or behavior is considered bribery or corruption, you should speak to the Head of Legal by emailing compliance@on24.com. If you wish to report any matters anonymously or confidentially, then you may do so by following the procedure outlined in the ON24 Code of Business Conduct & Ethics.
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) because 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 you believe that you have received detrimental treatment after reporting a concern or refusing to accept or offer a bribe, you 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. You 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. You 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
You are required to complete annual anti-bribery and anti-corruption training and must attest that you have read, understand, and will comply with this Policy.
Last Reviewed: September 2025