Code of Conduct

Code of Conduct

Cloud Raptor Digital Pty Ltd (ABN 97 656 375 245)


Acknowledgement of Country 
   1. Preamble 
   2. Definitions 
   3. Purpose 
   5. Obligation of the Company 
   6. Questions and Feedback 
   7. Other Relevant Policies 
   8. Effective Date 
Appendix A - Gift Register 

Cloud Raptor acknowledges the Aboriginal and Torres Strait Islander peoples as the Traditional Custodians of the lands on which we work and live. We pay our respects to their cultures, Elders past and present and honour their continuing connection to land, waters and community.

  1. Preamble
    1. The Company is an Australian proprietary company registered in 2022 in New South Wales. The Company's registered address is 19 Garden St, Eastlakes, New South Wales 2018, Australia.
    2. The Company operates a cloud digital transformation firm, focusing on a range of cloud-based advisory and implementation solutions for managed and professional services. The Company has clients all across the globe.
    3. This Code applies to all the Company's subsidiary entities, staff, agents, and Suppliers (collectively referred to as Agents) and all must abide by this Code.
  2. Definitions
    1. Anti-Bribery officer refers to Mervyn Small. Details are as follows:
      1. Email:
      2. Phone: 0410550702
    2. Bribery includes giving anything (even of low value) to influence a third-party to perform their job improperly or to influence their decision, or as a reward for doing their job improperly or allowing their decision to be influenced.
    3. Code refers to this Code of Conduct.
    4. Company refers to Cloud Raptor Digital Pty Ltd (ABN 97 656 375 245).
    5. Conflict of interest refers to whenever an Agent’s private interests interfere or conflict in any way (or even appear to interfere or conflict) with the interests of the Company.
    6. Fraud refers to deception (as defined in the Crimes Act 1900 No 40), obtaining property belonging to another and obtaining financial advantage or causing financial disadvantage to another person.
    7. Facilitation Payment refers to a small payment of $100.00 to a government official to facilitate a routine action. For example, speeding up the unloading of goods, or customs clearance.
    8. Gift refers to any item or form of entertainment either offered or received by the Company.
    9. Government Official means a person holding public authority, responsible for a public service mission or holding a public service office.
    10. Hospitality covers (but is not limited to) invitations to lunch, dinner, sporting events, trips abroad, payment for hotel accommodation, flights and similar activities.
    11. Kickback means the return of a sum paid (or due to be paid) as a reward for fostering a business arrangement.
    12. Supplier means any organisation or person who provides the Company with goods or services and includes any sub-contractors, agents, related entities and consultants.
    13. Supply chains are products and services (including labour) that contribute to the Company's products and services. It includes products and services sourced in Australia or overseas and extends beyond direct Suppliers.
    14. Modern Slavery describes situations where coercion, threats or deception are used to exploit individuals and undermine or deprive them of their freedom.
  3. Purpose
    1. This Code is in line with the Company's core values which are as follows:
      1. CUSTOMER CENTRIC – Putting customers 1st – The Company focus on outcomes.
      2. PASSIONATE – Perpetuating a culture built on respect, inclusion, and equality.
      3. INTUITIVE APPROACH – Solutions over 'shoehorning'.
      4. UNIQUE EXPERIENCE – Customer and employee Experience is everything.
      5. DIVERSITY – Diversity is at the core of the Company's work culture.
  4. Fundamentals
    1. Complying with all laws
      1. Agents should comply with all of the laws of the jurisdictions in which the Company conducts or is otherwise involved in business or business activities.
    2. Conflicts of Interest
      1. Agents must avoid Conflicts of Interest that impact or may impact the Company.
      2. Agents must not take for themselves personally, opportunities that otherwise belong to the Company.
      3. Any Agents who become aware of a conflict or potential conflict must bring any conflict or potential conflict to the attention of the Anti-Bribery officer.
    3. Gifts and Hospitality
      1. No Gift should be offered, given, provided or accepted by any Agent or family member of an Agent unless it:
        1. is not a cash Gift, and is given in an open and transparent manner for the sole aim of building a general relationship and understanding;
        2. is consistent with customary business practices;
        3. is not intended, and could not be construed as, an attempt to influence improperly the performance of the recipient’s role or function;
        4. is not excessive in value;
        5. cannot be construed as a bribe or payoff; and
        6. does not violate any laws or regulations.
      2. If an Agent is unsure whether something constitutes a Gift or Hospitality they should check with the Anti-Bribery officer.
      3. The purpose of Gifts in a commercial setting is to create goodwill and sound working relationships, not to gain unfair advantage.
      4. Gifts above AUD $50 outside the Company’s regular practices should be recorded in the Gift Register, attached as Appendix A.
      5. All Agents should report by email all Gifts given or received to the Anti-Bribery officer within 5 business days of giving or receiving them.
      6. This Code prohibits any Hospitality given with the intention of improperly influencing a third party to give the Company or to the Company a favour. This includes Hospitality given after the event, as a reward for business or a favour.
    4. Anti-bribery and Anti-Corruption
      1. Accepting or offering a Kickback violates this Code.
      2. Bribery is a criminal offence. Agents should never offer, give, request or accept a bribe. Agents should never authorise nor allow any third-party working with or for the Company, to pay bribes on the Company’s behalf.
      3. Agents must never pay a Facilitation Payment, as they are bribes if they are not official fees. Employees must report any Facilitation Payment that they are requested to make or that they have made to the Anti-Bribery officer as soon as possible.
      4. Agents must deal fairly with the Company’s customers, competitors, officers and employees and with all regulatory authorities with which the Company deals.
      5. The Company complies with all applicable financial reporting and accounting regulations.
      6. The Company pays all relevant taxes in the jurisdictions in which it operates.
      7. The Company complies with its taxation obligations.
      8. Agents must not assist or facilitate a third party to commit tax evasion. Assisting others to evade taxes is a criminal offence in many jurisdictions and could give rise to criminal liability for both the Agent and the Company.
      9. Agents should report any possible or actual breaches of this Code relating to Bribery to the Anti-Bribery officer.
    5. Whistleblowing
      1. Agents are encouraged to talk to the Anti-Bribery officer about observed illegal or unethical behaviour and, when in doubt, about the best course of action in a particular situation.
      2. Agents aware of illegal or unethical behaviour should report this behaviour to superiors. It is the responsibility of Agents to report any actual or presumed misconduct or violations of the law or ethics standards.
    6. Fraud
      1. There is no tolerance for Fraud involving any Agents or third parties with a business association with the Company.
      2. Actions that are prohibited under this Code include, but are not limited to:
        1. misappropriation of funds, securities, supplies or other Company assets;
        2. impropriety in the handling or reporting of money of financial transactions and statements;
        3. disclosing confidential or proprietary information to outside parties;
        4. accepting or seeking anything of material value from contractors, clients, third parties or persons providing services to the Company; or
        5. destruction, removal or inappropriate use of records and intellectual property.
      3. Agents that become aware of any actual or alleged Fraud should report this to superiors.
    7. Government Officials
      1. Agents are encouraged to talk to the Anti-Bribery officer about how to interact with Government Officials.
      2. Agents should avoid providing any financial or non-financial benefits to Government Officials, or contact the Anti-Bribery officer before offering or providing any gifts, meals, or entertainment to Government Officials.
      3. Any conflict of interest between an Agent working with a Government Official should be immediately reported to the Anti-Bribery officer before continuing the working relationship.
      4. Any information provided by a Government Official should be treated as confidential information that must not be disclosed to anyone outside the Company, unless otherwise stated.
      5. When interacting with Government Officials, the expectation is that Agents will:
        1. comply with applicable laws, regulations, policies, procedures and good business practices;
        2. act with integrity and openness;
        3. conduct business in an ethical and safe manner; and
        4. not discuss dealings with Government Officials to the media without approval.
  5. Obligations of the Company
    1. Should the Company become aware that any Agent has violated or is in breach of this Policy, the Company will:
      1. contact the relevant authorities should they be needed; and
      2. seek legal assistance.
    2. All concerns and reports will be thoroughly investigated.
  6. Questions and Feedback
    1. If an individual has questions regarding this Code or any concerns relating to Modern Slavery, please contact the Company's Anti-Bribery officer.
    2. The Company encourages individuals to provide feedback and suggestions. Individuals can provide said feedback and suggestions via the Company's Anti-Bribery officer.
  7. Other Relevant Policies
    1. In addition to this Code, the Company also aim to ensure compliance through policies such as its:
      1. Bullying, Discrimination and Harassment Policy;
      2. Modern Slavery Policy;
      3. Anti-Bribery and Corruption Policy
  8. Effective Date
    1. This Code is effective from 12/01/2023
    2. The Code will be reviewed on an annual basis or or earlier if any significant changes occur, and notification of revisions of the Code will be communicated to users. A copy of the Code will be available from all the Company’s offices and on its website at
    3. This Code supersedes any previous Code.

Appendix A – Gift Register

Gift ReceivedDateGiven ByOrganisationReason for GiftValue/Estimated ValueInvoice

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