Sphere is committed to conducting business responsibly, ethically, and in compliance with applicable laws and regulations. Integrity, transparency, and accountability guide how we operate and how we engage with employees, contractors, partners, and suppliers.
The following policies outline Sphere’s commitment to ethical business practices.
Sphere maintains a zero-tolerance approach to bribery and corruption and is committed to conducting business ethically and transparently.
Bribery involves offering, giving, receiving, or soliciting anything of value with the intention of influencing a decision, action, or outcome in the performance of official or business duties. This may occur directly or indirectly and may include gifts, payments, favours, or other benefits intended to gain an improper advantage.
Sphere does not offer, request, give, or accept bribes, kickbacks, or improper payments in any form. Facilitation or expediting payments intended to accelerate routine actions or secure preferential treatment are also prohibited. Legitimate business hospitality and promotional activities may occur in the ordinary course of business, provided they are reasonable, proportionate, transparent, and not intended to improperly influence a decision or outcome.
Employees, contractors, and representatives must:
Individuals will not face adverse consequences for refusing to make or receive an improper payment, even if this results in lost business opportunities.
Bribery and corruption are serious offences under Australian and international law, and breaches of this policy may result in disciplinary action and legal consequences.
Sphere also expects suppliers, contractors, consultants, and other business partners acting on its behalf to conduct business in accordance with applicable anti-bribery and corruption laws.
Sphere complies with all applicable economic sanctions laws and regulations, including those administered by the Australian Department of Foreign Affairs and Trade (DFAT) and other relevant authorities.
We do not conduct business with individuals, organisations, or jurisdictions that are subject to applicable sanctions restrictions.
Sphere takes reasonable steps to identify and screen customers, suppliers, and partners to ensure compliance with sanctions requirements. Where sanctions restrictions apply, Sphere will decline or suspend business activities that would breach those obligations.
Sphere complies with applicable Australian export control laws and international regulations governing the export or transfer of goods, software, and technical information.
Certain technologies, equipment, or technical data may be subject to export control restrictions. Sphere takes appropriate steps to ensure that controlled items are not exported or transferred in violation of applicable laws.
Where required, the appropriate licences, permits, or approvals must be obtained before exporting controlled goods, software, or technical information to another country or providing access to restricted technologies.
(Fraud, Money Laundering and Tax Evasion)
Sphere is committed to preventing financial crime in all forms, including fraud, money laundering, and the facilitation of tax evasion.
Fraud includes any dishonest act intended to obtain an improper financial or personal benefit, such as falsifying records, misrepresenting information, theft, or misuse of company resources.
Money laundering involves disguising the origins of illegally obtained funds. Sphere conducts business only with reputable customers and partners and may review or decline transactions that appear suspicious or inconsistent with legitimate business activity.
Sphere complies with all applicable tax laws and maintains accurate financial records to ensure proper tax reporting. Employees, contractors, and partners must not knowingly participate in arrangements intended to evade taxes or conceal taxable income.
Any suspected financial misconduct should be reported to management or appropriate internal channels and will be reviewed and investigated where appropriate.
Sphere promotes awareness of ethical and compliance obligations among employees and personnel involved in its operations and encourages responsible decision-making consistent with these standards. Management is responsible for fostering a culture of integrity and supporting compliance with applicable laws, regulations, and company policies.
Sphere periodically reviews and updates its ethics and compliance practices to ensure they remain aligned with applicable legal requirements and evolving industry standards.