Minimum functionality for private distribution?

I have a customer who wants to give his employees an iPad that does nothing other than display some fixed videos and PDF files. The customer has an Apple Business Manager account an an MDM. The solution we discussed is that my company would build their content into a simple app, distribute it to them via private distribution in the app store, and they would use their MDM to put it on their iPads in Single App Mode.

My concern is that Apple will still need to review the app and may reject it on the grounds that it violates the "Minimum Functionality" rule (4.2). Is this rule enforced even for B2B apps that are destined for private distribution?

Thanks, Frank

Logically, the rule should not be as strict for private distribution. But if it is just content, wouldn't hosting it on customer's servers for a web access be an easier solution ?

Minimum functionality for private distribution?
 
 
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