Purchasing external license seats that are applied in-app

Question on the monetization:

I have an app which I sell to businesses.

  1. The businesses would be some number of license seats.
  2. They distribute those license codes to their employees.
  3. The employees download my app for free, apply their license code, and then have unlimited use of the app.
  4. For those who download the app without the license code, they have limited use of the app.

This is the freemium model, except the license seats are purchased external to the app en masse by the business so that their employees don't have to buy them individually and file for individual reimbursement.

This seems like it fits squarely in the gray area of Apple's monetization policies. Am I allowed to do this?

Purchasing external license seats that are applied in-app
 
 
Q