Workers were paid a piece rate based on the amount of asparagus that they picked, and weren't paid minimum wages and holiday entitlements.
It was found some of the employee's wages were being calculated based on how much asparagus they picked at $2.50 a kilo.
According to the ERA, there are four different types of breaches by Gray.
A failure to pay minimum wage for 12 employees, failure to obtain consent for deductions from wages for 11 employees, failure to provide for public holidays and failure to keep compliant holiday and leave records.
There are 13 employees affected and a total of 47 separate beaches.
Horticulture sector inspector Kevin Finnegan earlier told the Herald there was no system in place to make sure employees were earning at least minimum wage.
He said they also found pay was being deducted for things like airfares and accommodation without the workers' consent.