BUSINESS ETHICS, ANTI-BRIBERY & COMPLIANCE
Open Spatial conducts its business on the basis that dealings with customers, government organisations, suppliers and business partners must be lawful, fair and transparent.
These standards apply to our directors, employees, contractors, agents and other parties acting on Open Spatial's behalf. They apply to our activities in Australia and to business conducted internationally.
Open Spatial provides software and professional services to government, utilities, infrastructure organisations and other customers. Because a significant part of our work involves public-sector organisations, we place particular importance on appropriate conduct when dealing with government customers and officials.
ETHICAL BUSINESS CONDUCT
Open Spatial expects business to be conducted honestly and without deception, improper influence or undisclosed conflicts of interest.
We expect our people to comply with applicable laws, deal fairly with customers and suppliers, keep appropriate business records and raise concerns where conduct does not meet these standards.
The same principles are considered when we select and work with suppliers, contractors and other business partners.
ANTI-BRIBERY AND CORRUPTION
Open Spatial does not tolerate bribery or corruption.
No director, employee, contractor, agent or other person acting for Open Spatial may offer, promise, authorise, provide, request or accept a bribe, kickback, secret commission or other improper benefit.
This applies whether the proposed benefit is financial or non-financial and whether it is offered directly or through another person or organisation.
A payment or benefit must never be used to improperly influence a business decision, secure an unfair advantage, obtain or retain business or reward someone for acting improperly.
Open Spatial expects these standards to be followed wherever we conduct business and requires compliance with applicable anti-bribery and anti-corruption laws.
GOVERNMENT AND PUBLIC-SECTOR DEALINGS
Additional care must be taken when dealing with government and public-sector customers.
For the purposes of these standards, a Government Official includes an employee, officer or representative of a national, state or local government, government department or agency, government-controlled organisation, public utility, public authority or public international organisation.
No payment, gift, hospitality, benefit or other thing of value may be offered to a Government Official for the purpose of influencing an official decision, securing preferential treatment or obtaining an improper business advantage.
The fact that a payment, gift or customary practice may be common in a particular country or industry does not make it acceptable.
GIFTS, HOSPITALITY AND ENTERTAINMENT
Reasonable business hospitality can be a legitimate part of a commercial relationship, but it must never be used to influence a decision improperly.
Gifts, meals, hospitality or entertainment given or received in connection with Open Spatial business must be modest, infrequent and appropriate to the circumstances. They must not create an obligation, compromise independent judgment or give the appearance that favourable treatment is expected in return.
Cash and cash-equivalent gifts are not acceptable.
Particular care must be taken during tenders, procurements, contract negotiations and other decision-making processes. Gifts or hospitality involving Government Officials must also comply with the rules of the recipient's organisation. Where there is any doubt, the matter should be referred to management before anything is offered or accepted.
COMMISSIONS, AGENTS AND THIRD-PARTY PAYMENTS
Commissions, referral fees, rebates, success fees and other payments to agents, advisers, representatives or intermediaries must relate to legitimate services and have a clear commercial basis.
Such payments must be reasonable for the services provided, properly documented, approved through normal business processes and accurately recorded.
A third party must never be used to make a payment or provide a benefit that Open Spatial would not be permitted to provide directly. Payments must not be concealed through false invoices, unrelated expenses, personal accounts or other arrangements intended to disguise their true purpose.
Open Spatial may undertake due diligence before appointing agents, contractors, business partners or other third parties, particularly where the nature of the engagement presents an increased corruption or financial-crime risk.
FACILITATION PAYMENTS
Open Spatial does not permit facilitation payments or other unofficial payments made to Government Officials to speed up or secure routine government actions.
Requests for such payments should be refused and reported through the appropriate internal reporting channel.
CONFLICTS OF INTEREST
Employees and others acting for Open Spatial should avoid situations where personal, financial or other interests could improperly influence—or reasonably appear to influence—a business decision.
Actual or potential conflicts should be disclosed to management so that they can be considered and managed appropriately.
FRAUD AND FINANCE CRIME
Open Spatial has zero tolerance for fraud and expects customers, suppliers, partners and other external parties dealing with the company to act lawfully and transparently.
Fraud, false or misleading transactions, money laundering and deliberate concealment of improper payments are inconsistent with Open Spatial's business standards.
Business transactions should be supported by appropriate documentation and recorded accurately enough to identify their nature and purpose.
SUPPLIERS AND BUSINESS PARTNERS
Open Spatial expects suppliers and business partners to conduct their activities ethically, comply with applicable laws and maintain appropriate labour, human-rights and business practices.
Supplier and partner risk is considered in the context of the goods or services being provided, the location and nature of the supplier's operations and the potential exposure to ethical, corruption or modern-slavery risks.
Where appropriate, Open Spatial may request information about a supplier's policies and controls and may review or reconsider an engagement where serious concerns cannot be satisfactorily addressed.
HUMAN RIGHTS AND MODERN SLAVERY
Open Spatial does not tolerate forced labour, human trafficking, child labour or other forms of serious exploitation within its operations or supply chains.
We take a risk-based approach to identifying potential modern-slavery exposure, particularly where goods or services involve complex international supply chains, outsourced services or higher-risk jurisdictions.
Where concerns are identified, Open Spatial seeks to investigate them, take appropriate corrective action and improve controls to reduce the likelihood of recurrence.
RESPONSIBLE PROCUREMENT AND CORPORATE RESPONSIBILITY
Open Spatial considers ethical conduct, human rights, environmental impact, reliability and long-term value when selecting suppliers and purchasing goods and services.
Our approach reflects the nature of our business, including the use of cloud infrastructure, software, professional services and technology equipment.
We favour suppliers who demonstrate responsible business practices and seek to reduce unnecessary environmental impact through digital delivery, efficient use of technology, reduced travel and responsible disposal of equipment.
REPORTING CONCERNS
Employees, contractors, suppliers and other stakeholders are encouraged to raise concerns about suspected bribery, corruption, fraud or other serious unethical conduct.
Concerns raised in good faith will be treated seriously. Open Spatial does not tolerate retaliation against a person who makes a genuine report.
Reports may be made to a manager or to Open Spatial's designated compliance contact.
Compliance contact: info@openspatial.com
RESPONSIBILITY, MONITORING AND REVIEW
Management is responsible for supporting a culture in which ethical conduct and compliance are understood as part of normal business operations.
Open Spatial periodically reviews its policies, supplier controls and risk-management practices and updates them where changes in legislation, customer requirements or business operations make this appropriate.
Relevant employees should be provided with information and training appropriate to their responsibilities, particularly where their roles involve sales, government customers, procurement, supplier management or third-party representatives.
LAST UPDATED
This policy was last updated on September 23, 2026.