This guide for GitLab Product Managers clarifies and expands on the Regulation FD Training.
GitLab Legal has put together a comprehensive framework to help team members determine which information is internal only and that which can be shared publicly. Following the SAFE framework will help you comply with the requirements of Regulation Fair Disclosure.
Please reach out to GitLab Legal in #legal and someone will be glad to assist you.
The following applies to GitLab artifacts that have product and specific feature information. Please remember these artifacts should only contain information that is SAFE. Links to various disclaimers are available in the "helpful legal references" section on this page.
|Topic||Disclaimer||Legal Review Required (Y/N)||Other Considerations|
|3 year direction videos||Y||Y|
|Company wide kickoff video||Y||N|
|Group Kickoff videos||N||N|
|Product demos, walk-through videos||N||N|
|Meeting recordings (e.g. Team calls, PM Weekly, Retrospectives)||N||N|
|General product handbook pages||N||N|
|Topic||Legal Considerations||Legal Review Required (Y/N)|
|New product launches (e.g GL Dedicated)||Y||Y|
|References to revenue||Y||Y|
|Publicly discussing a group's MAU in an issue||Not SAFE||We should avoid publicly disclosing MAU numbers|
If you need a review from Legal, please ping
@Heidi Loeffert in #legal. A response will be provided within 48 hours.
See the table above. If you are recording a video that requires a disclaimer but are not using a slidedeck, you may alternatively verbalize the disclaimer at the beginning of the video to avoid extra post-production work.
Guidelines covering the use of third-aprty materials are being prepared and will be linked here when ready.
The Third-party Trademark Usage Guidelines cover the use of third-party trademarks in GitLab (the product), and set out the process for adding new third-party logos to GitLab.
This advice covers the use of third-party trademarks in the context of comparative advertising.
In general, keep the issues and videos public. For issues that are of possible interest to investors keep private until publicly disclosed. Don't make public videos that contain earnings and other material information prior to these details being publicly available. Private issues that might find their way to an investor, analyst, or investment institution, are more likely to be in violation.
$cashtags are commonly used to reference anything that is financially related to a company (example). There is nothing wrong with using this symbol to reference or link to any financial information that has already been disclosed and distributed in an authorized public channel. For example, linking to a company's annual or quarterly statements published on their public website.
If the information is not SAFE, do not link to it or share it publicly.