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The purpose of this Anti-Retaliation Policy is to establish guidance for reporting ethics or compliance concerns or other inappropriate behavior while providing protection against retaliation for reporting in good faith. This Anti-Retaliation Policy is in addition to, and does not replace or supersede the anti-retaliation provisions set out in any policies that include anti-retaliation provisions.
Choosing to speak up about workplace concerns helps build a healthy, ethical, and compliant company, meets our company values of collaboration and transparency, and is part of our culture of compliance. GitLab Inc. (collectively with its subsidiaries, “GitLab”, “we”, “our”) does not tolerate retaliation against anyone who, in good faith, reports suspected misconduct, or anyone who provides assistance in an investigation. Coming forward with questions or concerns may sometimes feel like a difficult decision, but GitLab is committed to fostering an environment that does not deter individuals from engaging in frank, honest communication. In furtherance of those standards, this Anti-Retaliation Policy (this “Policy”) applies to all officers, employees, and direct and indirect contractors of GitLab and of its direct and indirect subsidiaries (each a “Team Member”). Compliance with this Policy is mandatory for every Team Member and member of GitLab’s Board of Directors (“Director”). In addition to this Policy, Team Members and Directors are subject to and must comply with other policies (including GitLab’s Code of Business Conduct and Ethics for Directors, Officers, Employees and Contractors (the “Code of Business Conduct and Ethics”)) and programs of GitLab, as applicable. We expect each Team Member and Director to read and become familiar with this Policy.
GitLab strictly prohibits any form of retaliatory action against any Team Member who in good faith raises issues, asks questions, makes reports, participates in an investigation, refuses to participate in suspected improper or wrongful activity, or exercises workplace rights protected by law (in each case, “Protected Activity”). Situations or behaviors that could lead to a Team Member engaging in a Protected Activity include, but are not limited to:
All forms of unlawful retaliation or penalization are prohibited. A non-exhaustive list of examples includes:
Any Team Member who participates, directly or indirectly, in any such retaliation will be subject to disciplinary action, up to and including termination. GitLab prohibits retaliation even if the concerns raised in good faith are not confirmed or substantiated following an investigation. However, a Team Member may be subject to disciplinary action, up to and including termination, if the Team Member knowingly made a false allegation, provided false or misleading information in the course of an investigation, or otherwise acted in bad faith.
This Policy does not exempt Team Members from the consequences of their own misconduct, and self-reporting such issues is not Protected Activity. This Policy also does not prevent GitLab from managing Team Member performance and/or addressing conduct issues after a Team Member has engaged in Protected Activity, so long as Protected Activity is not the reason for the performance management or disciplinary action.
If you believe you have been retaliated against, you should report it immediately. Complaints can be raised verbally or in writing. A report should be as detailed as possible, including the names of all individuals involved and any witnesses. The following are ways you can report retaliation:
GitLab will follow up on your report within the time period as required by local jurisdiction, which, depending on local requirements, could include an assessment to determine whether there is evidence that retaliatory conduct has taken place, appropriate action to address any wrongdoing (having due regard to the nature and seriousness of the matter concerned), or, where there is no evidence that retaliatory conduct has occurred, communication of the decision to the reporting Team Member.
If managers become aware of misconduct, they must address it as soon as they become aware and manage it seriously, confidentially, and fairly, whether or not there has been a written or formal complaint made.
Informed managers are expected to:
Team Member Relations is responsible for the administration of this Policy. If you have any questions regarding this Policy or questions about retaliation that are not addressed in this Policy, please contact teammemberrelations@gitlab.com.
Any Team Member, regardless of position or title, who has been determined, after investigation, to have engaged in retaliation in violation of this Policy, will be subject to discipline, up to and including termination of employment.
The employment terms set out in this Policy work in conjunction with, and do not replace, amend, or supplement any terms or conditions of employment stated in any collective bargaining agreement.
This Policy is not intended to restrict communications or actions protected or required by any applicable laws.
This Policy is in addition to, and does not replace or supersede the anti-retaliation provisions set out in any policies that include anti-retaliation provisions including, without limitation:
