The standards of behaviour expected of everyone who works for or represents Axiom Data: ethical behaviour, conflicts of interest, fraud, bribery and corruption, confidentiality and respectful workplace conduct.
Legislation and standards this policy gives effect to
Axiom Data places people into Australian Government agencies and builds systems that those agencies rely on. Our reputation rests entirely on how our people behave. This Code sets out the minimum standards of ethical and professional conduct that apply to everyone who works for, with, or on behalf of Axiom Data, and it gives effect to our obligations under the Commonwealth Supplier Code of Conduct.
The Code is not a complete list of rules. Where it is silent, we expect people to act honestly, lawfully, with care and diligence, and in a way that would withstand public scrutiny.
This policy applies to Ontology Analytics Pty Ltd, trading as Axiom Data (Axiom Data) and to every director, employee, labour-hire worker, contractor and agent engaged by Axiom Data, whether working at Axiom Data's premises, remotely, or on placement at a client site. Where a worker is placed with a client, this policy applies alongside the client's own policies; where the two differ, the worker follows the stricter requirement and raises the difference with Axiom Data.
Everyone covered by this Code must:
A conflict of interest exists where a personal interest, relationship or outside engagement could influence, or could reasonably be seen to influence, how a person performs their duties. Conflicts may be actual, potential or perceived, and all three must be disclosed.
Examples include: holding a financial interest in a client, supplier, competitor or another BuyICT seller; being engaged as a contractor by a Commonwealth agency through another seller while holding a role at Axiom Data; a close personal relationship with a client decision-maker, a candidate under assessment, or a partner contact; and any outside employment that competes with or could compromise work for Axiom Data or a client.
Every director, employee and placed worker must disclose a conflict in writing to the Director as soon as they become aware of it, using the conflict of interest declaration on the Employee Resources page. Disclosures are recorded on the Conflict of Interest Register, assessed, and managed through one or more of: written disclosure to the affected client; removal of the person from the relevant decision, assessment or engagement; independent review of the decision; or, where the conflict cannot be managed, divestment or cessation of the outside interest.
Specific standing arrangements are set out in the Conflict of Interest Policy (POL-02), including the disclosure of any director or owner who is personally engaged by a Commonwealth agency through another labour-hire provider.
Axiom Data has zero tolerance for fraud, bribery and corruption in any form. No person covered by this Code may:
We give effect to the Commonwealth Fraud and Corruption Control Framework in the way we operate: candidate qualifications, clearances and referees are verified before submission; timesheets are approved by the client before invoicing; two people review every invoice to a Commonwealth agency; and the Director is accountable for the fraud and corruption controls set out in this Code.
Suspected fraud or corruption involving a Commonwealth official or contract may be a matter for the National Anti-Corruption Commission. Axiom Data will report such matters where required and will cooperate fully with any investigation.
In the course of their work, people at Axiom Data receive confidential information belonging to clients, candidates, partners and Axiom Data itself, including Commonwealth information that may be security classified or official. Everyone covered by this Code must:
Candidate information, including resumes, clearance details and rates, is confidential. Axiom Data never discloses one candidate's or partner's commercial information to another.
Axiom Data is committed to a workplace, including every client site at which we place people, that is free from bullying, harassment, sexual harassment, discrimination, victimisation and vilification. Discrimination on the basis of race, colour, sex, sexual orientation, gender identity, age, disability, marital status, family or carer responsibilities, pregnancy, religion, political opinion, national extraction or social origin is unlawful and prohibited.
Everyone must treat colleagues, client staff, candidates and members of the public with courtesy and respect, and must not engage in conduct that a reasonable person would consider offensive, intimidating, humiliating or threatening. Axiom Data has a positive duty under the Sex Discrimination Act 1984 to take reasonable and proportionate measures to eliminate sexual harassment, and this Code, our induction and our incident procedures are part of meeting that duty.
A person who experiences or witnesses disrespectful conduct should report it under the Incident Reporting Procedure (POL-05). Reports are taken seriously, handled confidentially and investigated promptly.
People on placement must not make public comment on behalf of a client agency, and must comply with the agency's policies on public comment and social media. No person may post or share information about a client, its systems or its work on social media or elsewhere without written authority. Media enquiries about Axiom Data are referred to the Director.
Anyone who believes this Code has been breached, or who has a concern about conduct at Axiom Data or on a placement, is expected to raise it. Concerns may be raised with the Director in person, by phone, or by email to [email protected], or anonymously using the incident form on the Employee Resources page. Matters involving a Commonwealth agency may also be raised directly with that agency, and disclosures about Commonwealth wrongdoing may attract protection under the Public Interest Disclosure Act 2013 or the NACC Act 2022.
Axiom Data prohibits any form of reprisal against a person who raises a concern in good faith. Reprisal is itself a breach of this Code.
Every employee and placed worker is given this Code on engagement, confirms in writing that they have read and understood it, and is reminded of it at each annual review. Managers are responsible for modelling the Code and for acting on breaches.
A breach of this policy is a serious matter. Depending on the circumstances it may result in counselling, a written warning, removal from a client placement, termination of employment or engagement, and, where the law requires, referral to the relevant authority. Axiom Data will not take adverse action against anyone for raising a genuine concern in good faith.
This policy is owned by the Director and is reviewed at least annually, and sooner if legislation, a client requirement or an incident shows the need. The current version, effective date and next review date are recorded in the policy register on the Employee Resources page.
Code of Conduct and Ethics Policy · POL-01 v1.0 · Ontology Analytics Pty Ltd, trading as Axiom Data (ABN 36 653 416 856) · Approved by Atif Mahmood, Director · Effective 12 October 2026