Brumby Pay is committed to ethical, transparent, and lawful use of its platform. To uphold Australian Consumer Law, protect vulnerable communities, and meet regulatory expectations, Brumby Pay applies strict controls on how rewards can be used in high-risk or sensitive industries.

​

This policy applies to all users of the Brumby Pay platform, including businesses issuing invoices (creditors), bill payers, and other third-party stakeholders.
 

Purpose of Restrictions:

• Prevent misuse of reward logic in sensitive or regulated industries

• Avoid incentives that could distort access to essential services or financial decisions

• Align with ACL protections, especially against unconscionable conduct

• Maintain Brumby’s integrity and compliance position
   

Our Approach:

Brumby Pay maintains a restricted sector framework that governs the use of rewards in industries that:
 

• Serve vulnerable populations

• Provide essential or government-funded services

• Operate under financial or ethical scrutiny
   

This framework ensures reward use is neutral, non-inducive, and not applied in contexts where payment behaviour could be improperly influenced.
 

What This Means in Practice:

• Brumby Pay screens all users and invoice types as part of our onboarding process

• Some industries are subject to additional review before approval

• In high-risk sectors, reward access may be restricted or disabled

• Messaging is controlled to avoid pressure, urgency, or misleading tone
   

Legal & Regulatory Alignment:

Our restricted sector controls support compliance with:
 

• Australian Consumer Law

• ACCC guidelines on fair treatment of vulnerable consumers

• Relevant sector-specific codes and standards
   

A full version of our sector framework is retained internally for audit and regulator review upon request to approved entitites.
 

Final Notes:

Brumby Pay rewards are designed to acknowledge voluntary, timely invoice payments, not to alter financial decisions or add pressure. We do not engage in collections, inducement, or high-risk incentives. Sector safeguards are a key part of maintaining trust and legal integrity.

If you are unsure whether your industry is eligible for Brumby Pay rewards, please contact us through support@brumbypay.com.au

​​

© 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.