Effective from January 2026

Approved by: Chief Operations Officer

At a Glance

From time to time, as workers and employees build relationships with participants, vendors or any other external party it is understood that gifts may be offered as a sign of appreciation or as a favour. This policy provides an outline of the process for accepting gifts to ensure that all activities regarding gifts and favours are conducted with ethics and fairness.

Scope

All workers and employees within Thrive Group Australia.

Objective

To provide a clear guideline for accepting gifts and the approvals required before anything is officially accepted.

Definitions

• Gift - something given voluntarily without payment in return, as to show favour toward someone, honour an occasion, or make a gesture of assistance; a present.
• Favour - an act performed out of good will, generosity, or mercy.

Policy Statement

• All workers and employees must not accept, directly or indirectly, payments, loans, travel or accommodation offers, gifts, entertainment or any other benefits from any customer, supplier or entity with which Thrive Group Australia conducts, or may conduct, business if such gifts or benefits are likely to influence (or be perceived to influence) judgement.
• In cases where a potential conflict of interest exists, in addition to handling the transaction competitively and without bias, workers and employees must provide full details of the potential conflict of interest and the proposed method of dealing with the potential conflict of interest to their Manager for approval.
• If gifts or benefits have been received the worker or employee will need to report the receipt of the gift or benefit to their Manager immediately.
• Acquisition from a supplier, in which a worker or an employee has an interest, is prohibited, unless full details of the background facts are given in writing to, and approved by, the worker or employee’s Manager prior to any steps being taken in relation to the proposed acquisition.