1. Governance
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. maintains a governance structure with defined roles, responsibilities and escalation, including oversight of risk and compliance.
2. Accountability
Senior management is accountable for the effectiveness of the control framework and for fostering a culture of compliance.