Brumby Finance Pty Ltd, trading as "Brumby Pay" is committed to operating ethically, fairly, and in full compliance with Australian law. This Conduct & Ethics Statement outlines the principles that guide Brumby’s business conduct, platform use, and interactions with clients (creditors), payers (businesses or individuals), and other stakeholders. It reflects our commitment to regulatory alignment, including with ASIC, ACCC, OAIC, and the ATO.

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Platform Overview:
Brumby Pay is a Software-as-a-Service (SaaS) platform that enables businesses to offer non-cash, milestone-based reward opportunities to customers who voluntarily pay invoices on time.

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• Rewards are issued automatically when predefined platform-wide milestones are reached (e.g. every 100th invoice paid).

• There is no element of chance, no entry, and no change to legal invoice terms.

• Brumby Pay is not a collections agency, credit provider, remitter, or financial institution.

• Brumby Pay does not engage in debt recovery, enforcement, inducement, or financial intermediation.

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Legal and Regulatory Compliance:
 

• Brumby Pay prohibits misleading, deceptive, or unconscionable conduct in all platform messaging and use.

• Clients / Creditors must not use Brumby Pay to exert pressure or coercion on payers.

• Rewards must be disclosed transparently and never framed as conditional or compulsory.

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ASIC Act 2001 (Cth):

• Although not a financial services licensee, Brumby adheres to all standards relating to misleading and unconscionable conduct.

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Privacy Act 1988 (Cth) & Australian Privacy Principles (APPs):

• Brumby complies with all APPs, including secure data storage, limited data use, and data minimisation principles.

• Personal information is only used to operate the platform and fulfil rewards. It is never sold or misused.

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Taxation Law (ATO Guidelines):

• Brumby Pay funds all rewards directly using platform commissions.

• Brumby Pay does not provide tax advice.

• Clients and recipients are responsible for determining any applicable GST, FBT, or income tax obligations.

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Ethical Use of Milestone Rewards:

• All rewards are fixed and deterministic, triggered solely by reaching a platform-wide milestone.

• No action other than voluntary invoice payment is required.

• Rewards are not lotteries, inducements, cash-backs, or discounts.

• Clients must not misrepresent rewards as a financial benefit or promotional offer.

• Brumby Pay issues and funds all rewards directly as part of the service.

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Platform Safeguards:
Brumby Pay maintains strong operational controls to prevent misuse:

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Full audit trails of all rewards and milestone logic

• Suppression of behaviour patterns suggesting manipulation (e.g. invoice splitting)

• Formal fraud review and escalation procedures

• A visible complaints process for both businesses and consumers

• Centralised governance of milestone logic to ensure integrity

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Transparency and Reporting:
Brumby Pay is committed to:

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• Transparent fee structures and reward logic

• Clear disclosure of milestone terms, triggers, and timelines

• Full cooperation with regulators in the event of a complaint or audit

• Periodic internal audits and compliance reviews

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Prohibited Conduct:
Brumby Pay and its clients must not:

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• Use the platform to coerce, harass, or pressure payers

• Present rewards as cash discounts, inducements, or credit

• Manipulate invoices or user accounts to trigger rewards

• Target vulnerable individuals with misleading messaging

• Misrepresent Brumby Pay’s role in the payment process

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Ongoing Commitment:
Brumby Pay will review this Statement:

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• Annually

• In response to material regulatory changes

• Upon request by a regulator or compliance body

• Following any significant platform updates

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Contact:
To raise a concern, report unethical conduct, or request compliance clarification, please contact:
support@brumbypay.com.au
Brumby Finance Pty Ltd

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© 2025 Brumby Finance Pty Ltd. All rights reserved.
This document is provided for general information purposes. It may not be reproduced, distributed, or used for commercial purposes without the prior written consent of Brumby Finance Pty Ltd.