1. Governance
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.
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.