Yes, this is generally considered a "pinned" connection.
However, if there were a small amount of moment, then you could justify it with a hand calc. I had a case where I had a very small equipment support column with a base plate like this. No seismic load. Minimal wind and gravity loads.
I ran a calculation demonstrating that the wind load could be handled by the moment resistance at the base. IMO, the column was perfectly safe. But, the lead engineer objected and we moved the anchor bolts out to a more traditional moment resisting location. I didn't have a problem with changing it for him because he was the project lead and he had ultimate responsibility for my work.