Purpose
Assess, approve, refuse and record gifts, meals, hospitality, travel, entertainment and similar benefits offered by or to Bitkaya personnel.
Steps
| # | Action | Details | Evidence |
|---|---|---|---|
| 1 | Confirm business purpose | Confirm a legitimate business purpose and whether the item is lawful, modest, reasonable, transparent and unrelated to improper influence. A gift or hospitality item may only proceed if it is lawful, modest and reasonable, linked to a legitimate business purpose, not intended to influence a decision, and capable of being openly disclosed and recorded if needed. If unsure, stop and ask Compliance. | Business purpose record |
| 2 | Prohibit excluded items | Prohibit cash or cash equivalents, personal loans or personal reimbursements, luxury travel or accommodation, influence-based benefits, benefits during sensitive live decisions (live licensing, approval, procurement, audit, enforcement, complaint, or investigation process), benefits for a decision-maker’s family and anything that would be difficult to explain in an audit or to the Board. | Refusal record |
| 3 | Allow routine modest refreshments | Allow routine low-value refreshments or modest business meals without formal Compliance approval only when no public official or live decision is involved and the item is clearly modest. | Register entry where required |
| 4 | Obtain line-manager approval | Obtain line-manager approval for non-sensitive items above the ordinary routine level and record them where required. | Manager approval record |
| 5 | Obtain Compliance pre-approval | Obtain Compliance pre-approval above internal thresholds, for public officials, regulators or state-linked parties, for travel or accommodation, repeated benefits, sensitive timing or uncertainty. | Compliance approval record |
| 6 | Handle unsolicited gifts | For an unsolicited gift received unexpectedly: do not use it immediately; tell your manager and Compliance; Compliance decides whether it may be kept, returned, surrendered, or donated. | Disposition record |
| 7 | Record in Gifts and Hospitality Register | Record required approvals, refusals, offers, receipts and disposition in the Gifts and Hospitality Register. Approvals, refusals, and register entries must be retained under Bitkaya’s normal recordkeeping rules. | Gifts and Hospitality Register entry |
| 8 | Escalate sensitive items | Escalate immediately if the item feels excessive, the timing is sensitive, the giver appears to expect a favor, the item is being kept off-record, travel or accommodation or unusual payment is involved, or a regulator or public official is involved. | Escalation record |
Exceptions and Escalation
Where any decision rule creates doubt, the item shall not proceed until Compliance has decided. Public-official and regulator matters always require Compliance approval.
Records
- Request and business rationale
- Manager or Compliance approval
- Refusal, return, surrender or donation record
- Gifts and Hospitality Register entry
- Supporting receipt or communication
Relationships
- Policy: POL-ABC-001 Anti-Bribery and Corruption Manual
- Process: PRC-FCI-001 Financial Crime and Integrity
- Control: CTRL-ABC-003 Ensure Gifts and Hospitality Are Approved and Recorded
Assurance
Runtime effectiveness results are maintained in Odoo and assessed through the Hermes workflow tracked in ISS-HERMES-001. This note defines design, ownership, evidence expectations and testing method; it does not contain a manually maintained operation, evidence or overall effectiveness rating.
- Frequency: per item and periodic register review
History
- 2026-07-28: Enriched steps with the full Gifts and Hospitality SOP (section 22): basic rule, always-prohibited list, simple decision rule, tiered approval rules, unsolicited-gift handling and escalation triggers.
- 2026-07-26: Created from sections 9, 10 and 22 of the approved ABC Manual.