Envato Anti-Bribery and Corruption Policy

Last Updated: 24 October 2024

At Envato we take our values seriously and are committed to maintaining high ethical standards in all of the work that we do. It is vital that you know about Envato’s commitment to anti-bribery and corruption, as we all have an important role to play in upholding a zero tolerance approach.

Policy statement

This Anti-Bribery and Corruption Policy (Policy) is a critical part of Envato’s delivery on its values of “Build our future”, “Community spirit”, “Embrace diversity”, “Make Envato proud” and “Make it happen”. These values underpin our commitment to creating commercial outcomes in an ethical way, with the utmost integrity and transparency.

Envato takes a zero tolerance approach to bribery and corruption. We will not tolerate any form of bribery or corruption in our business or in those we do business with. This zero tolerance approach extends to the conduct of all external parties who perform services for or on behalf of Envato. This includes, but is not limited to, our authors, customers and affiliates.

Our Envato Leadership Team (ELT) and Board of Directors are dedicated to maintaining the highest ethical standards, good corporate governance and compliance practices.

Scope

This Policy applies to:

Envato Pty Limited, together with its related bodies corporate and businesses (Envato); and
All Envato team members – including but not limited to directors, officers, employees, and contractors.

This Policy applies regardless of whether you are working for Envato in Australia, Mexico, the United States, United Kingdom or any other country.

We expect all external parties that we do business with (including suppliers, vendors, as well as community members, including authors and affiliates) to act ethically and in line with the spirit of this Policy.

Your role and responsibilities

As an Envato team member, you play a role in the prevention, detection and reporting of bribery and other forms of corruption. Your behaviour and conduct can directly impact Envato’s brand and reputation, and in living the Envato Values, we rely on all Envato team members to act ethically and with integrity.

You must:

Know and understand your obligations under this Policy;
Complete the required anti-bribery and corruption training (training will be overseen by the Legal and People Team);
Speak up if you observe any conduct that is not in line with this Policy. Talk to your relevant Envato Leadership Team (ELT) member if you see something you are not comfortable with or sure about. Of course, you can also speak to any other Envato Leadership Team (ELT) member, including the CEO or General Counsel. You can find out more information about whistleblowing from our Whistleblower Policy; and
Do not accept any item that can be interpreted to be a perk from any third party, including an author, customer, affiliate or supplier. For more information please see our policy on receiving gifts from vendors and suppliers.

Policy guidelines

Check out the definitions table at the end for more details on what key terms and concepts mean in this Policy.

Prohibition against bribery

Envato prohibits bribes in any form. You must never give, offer, promise, accept, request or authorise a bribe, whether directly or indirectly via a third party. Third parties are any external person or organisation that Envato team members come into contact with during the course of their work. Check out the Ethics and Compliance Guideline for more details.

Facilitation payments

A facilitation payment is a minor payment made to a government or public official for the purpose of expediting routine government action.

You can use legitimate fast-track processes to expedite routine government actions of a minor nature, which is recorded by the recipient, such as processing visas, but only with written approval from the Legal Team. You must never make such payments in cash, or make payments that are unofficial, improper or irregular.

Gifts, entertainment and other perks

As a general rule, we decline any gifts, entertainment, hospitality or other perks from our community members (including authors, customers and affiliates) or business partners (including suppliers and vendors).

If you have an exceptional reason to accept any such items, or if you receive any such item unexpectedly (and without an opportunity to decline it), make sure you refer to our policy on receiving gifts from vendors and suppliers and speak to your relevant Envato Leadership Team (ELT) member.

Dealing with government or public officials

You should never accept, give, offer, or cause the giving of a bribe to any government or public official, whether in Australia, Mexico, United States, United Kingdom or any other country. It does not matter whether you intended to influence a foreign public official, intended to obtain or retain the benefit, or actually obtain or retain that benefit – it is an offence.

Government or public officials include employees, officials, or contractors of government (including regulatory bodies), state-owned enterprises, military and police, or the executive, legislature and judiciary (including politicians and political candidates). Check out the definitions table at the end of this Policy for more details.

Besides working on customer leads in Enterprise, there should be no reason for any Envato team member outside of the Legal and Finance Teams to engage with governments, regulators and industry associations on behalf of Envato in Australia, Mexico, the United States, United Kingdom or any other country. If you work in any other area of the business, you must not engage with any government department, regulator or industry association, or purport to represent Envato in any formal public capacity, without the prior approval of your relevant Envato Leadership Team (ELT) member.

Secret commissions

Where you are acting on behalf of Envato with third parties as an agent or fiduciary, you must not receive a commission, which can be money or any other benefit, from that third party, without disclosing that payment first to Envato.

Due diligence on third parties

Sufficient due diligence should be conducted on third parties, including people or organisations acting on behalf of Envato, suppliers, and vendors. This should include verifying the identity of any such party, conducting criminal history checks and credit reference checks, and verifying licences where applicable (including against publicly available registers). Of course, it goes without saying that this includes any verification or due diligence processes required by law, regulator or any government regulatory authority too.

Due diligence allows us to assess if the third party is suitable to be associated with Envato and whether appropriate controls are in place to prevent and detect bribery and corruption. We need to ensure that the third parties we engage will not bribe or perform corrupt acts on Envato’s behalf, or for which Envato may otherwise be responsible.

Charitable fundraising

Fundraising activities for charities with ‘Deductible Gift Recipient’ status can be undertaken on behalf of Envato by Australian team members in accordance with our Fundraising Guideline (and Envato will match the funds raised subject to the limits set out in the guideline). Other approved charitable fundraising or donation schemes or events may also be offered from time to time.

Envato does not support fundraising or donations to organisations with primarily political or religious purposes. If you are responsible for organising any fundraising activity or donation scheme or event then neither you nor Envato (or any Envato team members) may receive or expect to receive, directly or indirectly, any associated benefit. If you’re unsure, ask your relevant Envato Leadership Team (ELT) member.

Sponsorship

From time to time Envato may sponsor certain organisations, teams and events. Envato does not support sponsorship of any organisations, teams and events with primarily political or religious purposes.

If you are responsible for organising any sponsorship, then neither you nor Envato (or any Envato team member) may receive or expect to receive, directly or indirectly, any associated material or substantial benefit, where that benefit is, or might reasonably look like, a bribe (again, see the definitions section). Certain benefits that do not fall into this category are acceptable – things like opportunities to spruik or promote Envato’s business or open roles at a sponsored event, for example.

If you’re unsure, please ask your relevant Envato Leadership Team (ELT) member.

Examples of bribery and corruption

Envato hires a consultancy firm that has connections with key decision-makers in a Mexican government agency. The consultancy is paid an unusually large fee for vague services, and the real purpose of this payment is to secure a government contract, this could constitute a kickback scheme.
While actively pursuing an Enterprise customer lead in the USA, a team member offers to have Envato contribute $1,000 to a fundraising event which is organised by the lead.
Envato is bidding for a contract with a large government department in Australia. A senior employee within the company offers expensive gifts, such as luxury items and lavish dinners, to the officials involved in the decision-making process.

Record-keeping

All accounts, invoices, memoranda, receipts and other accounting documents and financial records must be prepared and maintained with accuracy and completeness. Internal financial and commercial controls must be followed to evidence the business reason for making payments to third parties. No accounts should be kept ‘off-book’ and improper payments should not be disguised as legitimate payments.

Consequences of non-compliance

The penalties for failing to comply with anti-bribery and corruption laws are significant and can include:

serious fines and penalties for Envato;
individual liability for Envato team members (including fines and imprisonment); and
operational, brand and reputational costs.

You must avoid any activity that might breach this Policy. Any material breach of this Policy will be reported to the Envato Leadership Team (ELT) member and the Board of Directors, where appropriate, and responses will be proportionate to the breach.

Envato team members found to be involved in a breach could face disciplinary action, including potential termination of employment. Business partners found to be involved in a breach could have their contracts terminated.

How to raise a concern

Contact your relevant Envato Leadership Team (ELT) member or the Legal Team as soon as possible if you know of any suspicious behaviour or suspect that a conflict with, or breach of, this Policy has occurred, or might occur in the future. If a bribe or facilitation payment is requested from, or offered to you, you should refuse it and report the incident promptly to your relevant Envato Leadership Team (ELT) member or the Legal Team.

Of course, you can also speak to any other Envato Leadership Team (ELT) member, including the CEO or General Counsel.

Remember, we value speaking up. If you are unsure if something constitutes a bribe or corrupt behaviour, contact the Legal Team for guidance. We will take all reports seriously and will treat any report you make with confidence to the maximum extent possible.

You can also make any reports (either anonymously or not) under our Whistleblower Policy.

Monitoring and review

This Policy will be periodically reviewed to ensure that it is operating effectively and to assess if updates are needed.

Definitions

TERM	DESCRIPTION
Bribe	means anything of value that is offered, promised or provided to gain any business, commercial, contractual, regulatory or personal advantage. Bribes can take the form of gifts, loans, fees, rewards, hospitality, offers of employment or other advantages. A bribe might not always be of large value and is not limited to the payment of money.
Bribery	means the act of offering, promising, authorising, giving, requesting, or accepting a bribe to improperly influence someone (in either their personal or official capacity) to obtain or retain a business or personal advantage. For example, making improper payments to government or public officials, or paying secret commissions to an agent. Bribery can occur directly, or indirectly through a third party acting on behalf of Envato.
Corruption	is the abuse of entrusted power for money or personal gain.
Envato team member	means anyone who is employed by or works at Envato (whether permanent, fixed-term or temporary) and includes directors, officers, employees, contractors, agents, consultants, secondees and interns (wherever located).
Facilitation payments	are low value payments to government officials or employees designed to expedite or facilitate routine government actions, e.g. processing visas, permits and other actions of a non-discretionary nature. The payment is not intended to influence the outcome of a government official’s action, only its timing.
Government or public official	means members, employees, officials or contractors of:government and government bodies (including military and police);government or state-controlled companies;the executive, legislature or judiciary (including politicians and candidates for office);statutory officeholders;royal families; andpublic international organisations.
Political contribution	means gifts, payments, loans or anything else of value made to a political party, candidate or elected parliamentarian in national, federal, state or local government.
Third party	means any external individual or organisation that Envato employees come into contact with during the course of their work, and includes actual and potential clients, agents, contractors, suppliers, distributors, business contacts, joint venture partners, anyone acting in a fiduciary capacity, and government and public bodies (including their advisors, representatives and officials, politicians and political parties).