Purpose
Control corruption risk arising from public officials, state-linked parties, donations, sponsorships, political contributions, conflicts of interest and personal benefits.
Steps
| # | Action | Details | Evidence |
|---|---|---|---|
| 1 | Document public-official interactions | Document the legitimate business purpose and material details of interactions with public officials, regulators, supervisors, tax authorities, law enforcement, licensing authorities and state-owned entities. Minimum requirements include a legitimate business purpose for each interaction and appropriate documentation of material meetings or requests. | Interaction documentation |
| 2 | Obtain Compliance approval for benefits | Obtain enhanced review and Compliance approval for benefits, travel, hospitality, reimbursements or other value involving such parties. Do not proceed without Compliance approval; document the business purpose clearly; refuse anything that appears unofficial, personal, or influence-based. | Compliance approval record |
| 3 | Escalate unofficial payment requests | Escalate requests for unofficial payments, favors, expedited treatment or off-record arrangements immediately. Under no circumstances may Bitkaya provide anything of value to obtain or retain business improperly, influence a regulatory outcome, avoid a penalty, or secure preferential treatment. | Escalation record |
| 4 | Verify donations and sponsorships | Verify the recipient, purpose, legitimacy, approval and accounting treatment of charitable donations and sponsorships and confirm they are not linked to an improper advantage. Permitted only where: the recipient is legitimate and verifiable, the purpose is documented, there is no link to an improper advantage, the payment is appropriately approved, and the donation or sponsorship is accurately recorded. | Donation or sponsorship approval |
| 5 | Restrict political contributions | Prohibit political contributions on Bitkaya’s behalf unless permitted by applicable law and expressly approved by the Board. No political contribution may be used to influence regulatory treatment or obtain a business advantage. | Board-approved contribution record |
| 6 | Require conflict disclosures | Require disclosure of actual, potential and perceived conflicts, including outside business interests, financial interests in vendors, service providers, or counterparties, family or personal relationships with decision-makers or public officials, and personal benefits linked to company transactions. | Conflict disclosure record |
| 7 | Assess and manage conflicts | Assess and manage conflicts through proportionate disclosure, escalation, restriction, recusal, additional oversight or prohibition — Bitkaya shall record, assess, and manage conflicts through proportionate disclosure, escalation, restriction, or prohibition measures. | Conflict assessment and treatment record |
| 8 | Retain decisions and evidence | Retain decisions, approvals, disclosures and monitoring evidence. | Retained evidence file |
Exceptions and Escalation
No value may be provided to influence a regulatory outcome, avoid a penalty, obtain business or secure preferential treatment. Any uncertainty is escalated to Compliance before action.
Records
- Public-official interaction and approval record
- Donation or sponsorship due diligence and approval
- Board-approved political contribution record, where legally permitted
- Conflict disclosure, assessment and treatment
- Escalation and decision evidence
Relationships
- Policy: POL-ABC-001 Anti-Bribery and Corruption Manual
- Process: PRC-FCI-001 Financial Crime and Integrity
- Control: CTRL-ABC-004 Ensure Sensitive Interactions Contributions and Conflicts Are Controlled
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 event and periodic conflict review
History
- 2026-07-28: Enriched steps with the full content of sections 10, 11 and 12: public-official minimum requirements, donation permissibility conditions, political-contribution restriction, and conflict-disclosure categories.
- 2026-07-26: Created from sections 10, 11 and 12 of the approved ABC Manual.