Legal
Modern Slavery Statement
Ernora Pay
Effective Date: 11.06.2025
1. Introduction
This Modern Slavery Statement sets out Ernora Pay’s commitment to preventing modern slavery, human trafficking, forced labour, and related human rights abuses in its operations and, to the extent appropriate, in its business relationships and supply chains.
As a responsible financial services business, Ernora Pay recognizes the importance of respecting human rights, maintaining ethical standards, and taking reasonable steps to identify and mitigate risks associated with modern slavery.
2. Our Business and Operations
Ernora Pay is a Canadian Money Services Business operating in the financial services sector.
Our business activities include services such as:
- foreign exchange;
- money remittance;
- payment-related services;
- cross-border financial transactions and related operational support.
Our operating model is primarily digital and includes the use of third-party technology providers, service partners, and, where relevant, banking and payment counterparties.
3. Understanding Modern Slavery
For the purposes of this Statement, modern slavery may include serious forms of exploitation such as:
- human trafficking;
- forced or compulsory labour;
- debt bondage;
- exploitative child labour;
- servitude;
- sexual exploitation carried out through force, coercion, deception, or abuse.
Ernora Pay recognizes that modern slavery risks can arise in various sectors and may exist not only in direct employment relationships, but also through suppliers, service providers, intermediaries, customers, or other third parties.
4. Our Commitment
Ernora Pay is committed to conducting business in a lawful, ethical, and responsible manner. This includes a commitment to:
- maintaining zero tolerance for modern slavery and human trafficking in any form;
- supporting fair and lawful working practices;
- promoting respect for human rights and human dignity;
- avoiding knowingly entering into business relationships that involve forced labour, trafficking, or exploitative practices;
- taking reasonable action where concerns are identified.
5. Policies and Governance
Our broader compliance, risk, and governance framework supports this commitment. Depending on the nature of our operations, this may include internal policies and controls relating to:
- ethical conduct and responsible business practices;
- anti-financial crime compliance;
- supplier and third-party onboarding;
- customer due diligence and risk assessment;
- whistleblowing, escalation, and incident reporting;
- staff training and internal accountability.
Oversight of relevant compliance and risk matters is managed through Ernora Pay’s internal governance structure, with appropriate involvement from senior management and, where applicable, board-level oversight.
6. Risk Assessment
Ernora Pay considers the risk of modern slavery in light of the size and nature of its business, the jurisdictions in which it operates, and the third parties with whom it works.
Potential risk areas may include:
- outsourced services or vendors operating in higher-risk sectors or regions;
- business relationships involving complex or opaque ownership structures;
- customer activity connected to industries or jurisdictions that may present elevated exploitation risks;
- third-party support services where labour protections may vary.
As part of our broader compliance and business risk processes, Ernora Pay may assess and review such risks on a risk-based basis.
7. Due Diligence and Prevention Measures
To help reduce the risk of modern slavery, Ernora Pay may apply measures such as:
- risk-based due diligence on relevant third-party providers and service partners;
- contractual expectations relating to lawful and ethical conduct where appropriate;
- customer due diligence and enhanced review in higher-risk cases;
- internal escalation procedures where suspicious or concerning circumstances arise;
- review of business relationships where red flags are identified.
Where appropriate, we may decline, restrict, suspend, or terminate relationships or transactions that present unacceptable legal, ethical, or compliance concerns.
8. Employee Awareness and Training
Relevant employees may receive training or guidance appropriate to their role to help them understand:
- what modern slavery and trafficking risks may look like;
- how concerns may arise in financial services or third-party relationships;
- how to escalate suspected issues internally;
- the importance of ethical conduct and compliance with applicable laws and internal policies.
9. Reporting, Escalation, and Response
Ernora Pay seeks to maintain procedures for the reporting and escalation of suspected misconduct or human rights concerns. Where modern slavery or related exploitation is identified or reasonably suspected, actions may include:
- internal review and investigation;
- escalation to relevant compliance or management personnel;
- suspension or review of the relevant relationship or activity;
- preservation of relevant records or evidence where appropriate;
- notification to law enforcement, regulators, or other authorities where required by law or considered appropriate.
10. Continuous Improvement
Ernora Pay may review and develop its approach to modern slavery risk over time in light of:
- operational experience;
- changes in law or regulatory expectations;
- internal reviews and control enhancements;
- evolving best practices in governance, compliance, and human rights risk management.
11. Statement Review
This Modern Slavery Statement may be reviewed and updated periodically to reflect changes in Ernora Pay’s business operations, risk environment, or legal and regulatory requirements.
12. Contact Information
If you have questions regarding this Modern Slavery Statement or wish to raise a concern, please contact us at:
Ernora Pay
7404 King George Blvd., Suite 200
Surrey, Canada
MSB number: M23468645
Email: support@ernorapay.com