This is boilerplate which you'd also find at other companys as well. In fact, the language was almost identical to what I saw at IBM. General counsels at big

This is boilerplate which you'd also find at other companys as well. In fact, the language was almost identical to what I saw at IBM. General counsels at big companies share "best practices" at their own conferences dedicated for corporate laywers. I've been a guest speaker talking about open source issues at legal conferences where they were talking about best practices for OSS compliance; it's not an accident that many company's OSS policies are very similar. So policies like "require annual, mandatory training for anti-harassment training", and "how to communicate with care", etc., are going to be remarkably similar across companies.