iOS Offer Codes as a way to Gift a Subscription?

I am trying to figure out if it is against Apple Guidelines to use iOS 14 Offer Codes as a way to "Gift" an In-App subscription.

The way I was envisioning doing this is to generate Offer Codes that give users Free Access and use these codes as a separate In-App purchase that we manage the distribution of.

I can't find anything in the guidelines that prohibits this but I may be missing something. Any help is greatly appreciated.

Thanks in advance!

iOS Offer Codes as a way to Gift a Subscription?
 
 
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