Conflicts of Interest

This document sets out FLOWA PAY INC.'s policy position and control objectives, published for transparency and to support institutional due diligence. It is reviewed periodically and does not constitute legal advice. 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.

This policy sets out how FLOWA PAY INC. identifies, declares and manages conflicts of interest, so that decisions are made on their merits and can be shown to have been.

A conflict arises where a personal interest, relationship or outside activity could improperly influence, or appear to influence, a decision taken on behalf of the company. Common examples include a financial interest in a customer, supplier or competitor; a personal relationship with a counterparty or an applicant; outside employment or a directorship; gifts or hospitality that could place someone under obligation; and recruitment or procurement involving a connected person.

Perceived conflicts are managed as carefully as actual ones. The test is not whether the individual believes they can remain objective, but whether an informed outsider would reasonably doubt it.

Conflicts must be declared promptly on arising, and in any event before participating in the relevant decision. Declarations are made to management and recorded in a conflicts register maintained by the compliance function. Declaring a conflict is not an admission of wrongdoing; failing to declare one is a disciplinary matter.

Management is proportionate to the conflict and may include recusal from the decision, reassignment of the matter, additional oversight or approval at a higher level, information barriers, or in some cases requiring the outside interest to end. The measure applied and the reason are recorded alongside the declaration.

Gifts and hospitality must never be offered or accepted where they could improperly influence a decision, and anything beyond what is modest and customary must be declared and approved in advance. Nothing may be offered or accepted in connection with a live underwriting decision, a procurement process or a regulatory matter. See our Anti-Bribery & Anti-Corruption policy.

The conflicts register is reviewed periodically by the compliance function and reported to governance. Unmanaged or recurring conflicts are escalated. Concerns can be raised confidentially under our Whistleblowing Policy.