Anti-Bribery & Anti-Corruption

Draft for review. This document is an internal working template prepared to support commercial onboarding and institutional due diligence. It does not constitute legal advice and must be reviewed and approved by FLOWA PAY INC.'s legal and compliance functions before it is relied upon. FLOWA PAY INC. makes no representation that it holds any licence, authorisation or certification except the FINTRAC Money Services Business registration expressly stated in the Regulatory Disclosures.

FLOWA PAY INC. has zero tolerance for bribery and corruption and prohibits offering, giving, requesting or accepting any bribe or improper advantage.

Gifts and hospitality must be reasonable, proportionate, transparent and never intended to improperly influence a decision. Facilitation payments are prohibited.

Concerns must be reported through our Whistleblowing Policy. Breaches may result in disciplinary action.