Policies related to Gifts and Contributions
Gifts and Entertainment Policy
Overview and Purpose
This Policy applies to all GitLab Team Members, including employees, contractors, officers and members of its board of directors, as well as anyone acting on GitLab’s behalf. It provides guidance for making ethical decisions when giving or receiving gifts and entertainment to protect GitLab’s reputation, ensure legal compliance, and uphold our commitment to integrity.
Team Members must follow this Policy, in addition to GitLab’s Code of Business Conduct and Ethics Policy and the Anti-Corruption Policyand applicable laws and regulations.
Definitions
A “gift” is anything of monetary value, including swag, promotional items, gift baskets, event tickets (when the gift-giver is not present), or cash equivalents.
“Entertainment” refers to activities where both the giver and recipient participate together, such as business meals or attending sporting or cultural events. Customary refreshments other than those offered as part of a meal, such as water, coffee, and other non-alcoholic beverages, are not considered entertainment and are excluded from this Policy.
“Marketing Promotional Activity” includes product demonstrations, educational sessions, conferences, webinars, surveys, trade shows, digital marketing campaigns, content engagement incentives, lead generation activities, and similar business development initiatives designed to educate prospects about GitLab’s products and services.
A “government official” includes any employee or official of a government entity, government-owned or controlled business or entity, and political party or candidate, including their immediate family members. This definition is intentionally broad to ensure compliance with global anti-corruption laws and regulations. Examples include employees of public universities, state-owned hospitals, national telecom companies, government utilities, public transportation authorities, and government research institutes. When uncertain, seek guidance from the Ethics and Compliance team in the #ethics-and-compliance Slack channel.
General Requirements
When giving or receiving gifts and entertainment, Team Members should exercise good judgment and consider whether the exchange would create the appearance of improper influence. All gifts and entertainment must be:
- Reasonable and appropriate for the occasion;
- Infrequent and not part of a pattern;
- Given or accepted openly and transparently;
- Properly documented;
- Never intended to improperly influence business decisions;
- Not cash or cash equivalents like gift cards or gift certificates, except as specifically permitted under the Exception for Promotional Activities below; and,
- Consistent with local laws and customs.
Prohibited Activities
The following are never permitted:
- Cash or cash equivalents (except under the Exception for Promotional Activities);
- Excessive, lavish, or inappropriate gifts/entertainment;
- Gifts or entertainment given with a corrupt or improper purpose;
- Gifts or entertainment that would induce someone to act in breach of their duties;
- Gifts or entertainment during active procurement or negotiations (except under the Exception for Promotional Activities); or,
- Gifts or entertainment that would violate laws, regulations, or ethical standards, or embarrass GitLab.
Government Officials - Special Considerations
Providing gifts or entertainment to government officials presents significantly heightened legal and reputational risks for GitLab. Most countries have strict laws, such as the U.S. Foreign Corrupt Practices Act (“FCPA”) and UK Bribery Act, governing interactions with government officials, which are enforced with severe penalties for violations. Additionally, government employees at the Federal, State, and local levels in the United States are subject to rules that restrict their ability to accept gifts and entertainment.
For these reasons, GitLab restricts the provision of gifts and entertainment to government officials as follows:
- The total value of gifts or entertainment provided to a U.S. government official cannot exceed $20 USD (or the equivalent in local currency) per person per event. The combined total value of all gifts and entertainment provided to the same government official cannot exceed $50 USD per calendar year;
- The total value of gifts or entertainment provided to a foreign government official cannot exceed $80 USD (or the equivalent in local currency) per person per event, without pre-approval from GitLab’s Ethics and Compliance team using this form or the #ethics-and-compliance Slack channel;
- When submitting an expense report in Navan, Team Members must identify all government officials, including their (valid) email addresses, in the “Participants” field;
- Gifts and entertainment must never be intended to influence official actions;
- No gifts or entertainment should be provided during pending licensing, investigations, or regulatory matters; and,
- Team Members considering gifts or entertainment for state or tribal government officials may consult with the Ethics and Compliance team in the #ethics-and-compliance Slack channel to understand applicable local value thresholds and obtain approval for exceptions to the general limits where legally permissible.
In addition to the restrictions in this Policy, any gifts or entertainment provided to government officials must also comply with GitLab’s Public Sector Rules of Engagement and GitLab Federal Code of Ethics as applicable.
Marketing Promotional Activities Exception
GitLab Team Members may provide promotional incentives in connection with legitimate targeted marketing activities designed to build relationships with specific prospects, including product demonstrations, educational webinars, conference participation, survey incentives, content engagement rewards, lead generation campaigns, and digital marketing initiatives, and account-based marketing programs, subject to the following requirements and limitations:
Value Limits and Frequency
Tier 1 - Standard Prospects
- Maximum $25 USD per incentive
- Maximum 3 incentives per person per calendar year
- Maximum $75 USD total per person per calendar year
Tier 2 - Enterprise Prospects (deals >$100K ARR)
- Maximum $50 USD per incentive (or $25 USD if providing gift cards)
- Maximum 4 incentives per person per calendar year
- Maximum $150 USD total per person per calendar year
Campaign-Based Exception: Within a single defined marketing campaign (maximum 90 days), multiple touchpoints to the same prospect are permitted, provided each individual person’s total value doesn’t exceed their applicable tier limits and all individual annual limits are still respected.total value doesn’t exceed tier limits
Gift Card Restrictions:
While cash equivalents are generally prohibited, gift cards may be provided for targeted promotional activities, provided the gift card is:
- Never for government officials
- Maximum $25 USD (or equivalent local currency) per recipient
- Maximum one gift card per person per calendar year
- Only for legitimate targeted promotional activities as defined above.
Documentation Requirements: All targeted promotional activities must be recorded in a centralized system maintained by Marketing in coordination with Ethics and Compliance, including:
- Recipient name and company;
- Valid email address;
- Campaign/activity description;
- Date and incentive value; and,
- Campaign duration and objectives.
This register is subject to regular audit.
Broad-Reach Marketing Activities
Sweepstakes, Contests, and Similar Activities
Conference sweepstakes, contests, giveaways, and other broad-reach marketing activities designed primarily for brand awareness and lead generation (rather than targeted relationship building) are governed by separate rules and procedures established by GitLab’s Legal team.
Key Requirements:
- These activities do not fall under the Targeted Marketing Promotional Activities Exception described above and do not therefore count against the annual limits specified in that section;
- Cash and cash equivalents (including gift cards) are not permitted as prizes or incentives;
- All government official restrictions outlined in this Policy continue to apply; and,
- Must comply with GitLab’s standard approval processes for promotional games and all applicable laws.
See Marketing Guide: Collaborating with GitLab Legal; and Process for a Conference Sweepstakes
Interaction with Targeted Activities
Receiving a prize from a GitLab sweepstakes or contest does not disqualify an individual from participating in targeted promotional activities, nor does it count against their annual limits. However, all activities involving the same individual must still comply with applicable government official restrictions and other requirements of this Policy.
Accepting Gifts and Entertainment General Guidelines
Team Members may accept modest, occasional, and unsolicited gifts and entertainment from business partners when customary for the business relationship. Accepting should not create a sense of obligation or the appearance of impropriety.
Team members should never solicit gifts or entertainment, accept cash or cash equivalents, or accept gifts during sensitive business processes, such as contract negotiations. If you receive a gift that does not comply with this Policy, you should politely return it or seek guidance in the #ethics-and-compliance Slack channel.
Questions & Reporting
For questions about this Policy, contact the Ethics and Compliance team in the #ethics-and-compliance Slack channel or consult with your manager. For concerns or violations, use the channels described in our Whistleblower Policy. Non-compliance with this Policy may result in disciplinary action up to and including termination, subject to local law.
Reporting Concerns & Violations
Failure to comply with this Policy may result in non-reimbursement of unauthorized expenses and disciplinary action, up to and including termination, subject to local law. If you have any concerns, please seek guidance in the #ethics-and-compliance Slack channel or report the matter using any of the channels described in our Whistleblower Policy.
Charitable Contributions
GitLab supports nonprofit organizations through our Sustainability programs. GitLab team members may contribute to these efforts, or may choose to contribute to organizations of their own choice. However, as with political activities, you may not use company resources to personally support charitable or other non-profit institutions not specifically sanctioned or supported by the company. Please review the Philanthropy Policy for guidelines and instructions to request support.
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