Also and IANAL but as someone who lives in Victoria part of me really thinks you should have an actual lawyer go over your business model and just make sure you

Also and IANAL but as someone who lives in Victoria part of me really thinks you should have an actual lawyer go over your business model and just make sure you're kosher. I'd worry that there could be an interpretation that you're de-facto contracting employees, since you're effectively paying people to fulfil a service you're on-selling (the surveys) by allowing them to 'spend' the money on 'gifts' (to a charity, true, but I'm not sure it matters.) It may all be cool, but you really do want to be 100% certain about that.