LEGAL

Modern Slavery Policy

Last Updated: August 24, 2026

Brisk Pay’s commitment to preventing forced labour, child labour, modern slavery and human trafficking in our business and business relationships.

Brisk Pay is committed to conducting business ethically and responsibly. We do not tolerate modern slavery, forced labour, child labour or human trafficking in our operations or knowingly in the activities of organizations with which we do business.

1. Our Commitment

Brisk Pay expects people working for or with us to be treated fairly, lawfully and with respect for their fundamental rights.

We are committed to:

  • Conducting business with integrity

  • Complying with applicable employment, human-rights and forced-labour laws

  • Avoiding business relationships where we know there is involvement in forced labour, child labour, human trafficking or similar exploitation

  • Taking appropriate action where credible concerns are identified

Our approach may be reviewed as our business, suppliers, partners and applicable legal requirements evolve.

2. Our Business

Brisk Pay provides payment, financial technology and related services to businesses and customers.

Our business primarily relies on professional, financial and technology service providers rather than complex physical-goods supply chains. These may include:

  • Banks and financial institutions

  • Payment service providers

  • Technology and infrastructure providers

  • Identity and compliance providers

  • Professional advisers

  • Other operational service providers

We expect organizations we work with to conduct their activities lawfully and responsibly.

3. Partners and Service Providers

Brisk Pay may consider ethical, legal, regulatory and reputational risks when selecting and maintaining relationships with material partners and service providers.

Depending on the nature and risk of the relationship, this may include:

  • Reviewing relevant company and regulatory information

  • Considering the location and nature of the provider’s activities

  • Assessing material legal or reputational concerns

  • Requesting additional information where appropriate

  • Taking action where credible concerns regarding unlawful labour practices are identified

The level of review may vary depending on the nature, location and risk profile of the relationship.

Brisk Pay does not claim that every supplier or service provider is subject to the same level of review.

4. Financial Crime and Customer Controls

Brisk Pay maintains customer due diligence and financial crime controls as described in our Compliance & AML Programme.

These controls are primarily designed to meet financial crime and regulatory requirements but may also assist in identifying unusual activity, businesses or transactions that warrant additional review.

Where Brisk Pay identifies information that may indicate unlawful activity, including potential human trafficking or exploitation, we may conduct further review and take appropriate action in accordance with applicable law.

5. Raising Concerns

Employees, contractors, partners and other persons dealing with Brisk Pay are encouraged to raise concerns if they become aware of suspected:

  • Forced labour

  • Child labour

  • Human trafficking

  • Coercive or exploitative labour practices

  • Other serious human-rights concerns connected with Brisk Pay’s activities or business relationships

Concerns should be raised in good faith and will be handled appropriately and with due regard for confidentiality, applicable law and the rights of the individuals involved.

Where a concern is substantiated, Brisk Pay may take appropriate action, which could include further investigation, requesting remedial action, reconsidering a business relationship or referring matters to appropriate authorities where required.

6. Responsibility

Preventing exploitation is a shared responsibility.

Brisk Pay expects its personnel to:

  • Act ethically and lawfully

  • Remain alert to credible signs of exploitation

  • Avoid knowingly facilitating unlawful or exploitative activity

  • Raise concerns through appropriate internal channels

  • Cooperate with reasonable investigations where required

Management is responsible for ensuring that material concerns raised under this Policy are considered and addressed appropriately.

7. Compliance With Applicable Law

Brisk Pay will comply with applicable Canadian laws concerning forced labour, child labour, human trafficking and related matters.

Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act imposes specific transparency and reporting obligations on organizations that fall within its scope.

Where Brisk Pay becomes subject to reporting or other obligations under that legislation or other applicable laws, Brisk Pay will take appropriate steps to comply with those requirements.

8. Review of This Policy

Brisk Pay may review and update this Policy from time to time to reflect changes in:

  • Our business and operations

  • Material service-provider relationships

  • Identified risks

  • Applicable laws and regulatory expectations

The Last Updated date at the top of this Policy identifies the most recent revision.

9. Contact Us

Questions or concerns relating to this Policy may be directed to:

Brisk Pay
22420 Dewdney Trunk Road, Suite 300
Maple Ridge, BC V2X 3J5
Canada

Email: support@briskpay.ca