Purpose
Prevent concealment of bribery or corruption through inaccurate, unsupported or misleading financial and business records.
Steps
| # | Action | Details | Evidence |
|---|---|---|---|
| 1 | Require documented approval workflows | Require documented approval workflows for payments, expenses, reimbursements, commissions, consulting fees, credits and donations. | Approval workflow documentation |
| 2 | Confirm payment legitimacy | Confirm that each payment has a legitimate purpose, valid payee, appropriate invoice, evidence of services and required approvals. | Payment approval record |
| 3 | Confirm fees are justifiable | Confirm that commissions and consulting fees are commercially justifiable and consistent with documented deliverables. | Fee rationale record |
| 4 | Prohibit off-book arrangements | Prohibit off-book accounts, side arrangements, false descriptions, sham agreements and concealed or mischaracterized entries. Bitkaya prohibits any falsification, concealment, or mischaracterization of payments, invoices, commissions, reimbursements, contracts, approvals, or supporting documents. | Compliance confirmation |
| 5 | Review unusual financial items | Review unusual invoices, duplicate claims, round-sum charges, vague service descriptions, unrelated payees, offshore payment requests and unsupported reimbursements. | Exception review record |
| 6 | Escalate irregularities before payment | Escalate irregularities to Finance and Compliance before payment or reimbursement. Finance shall escalate financial irregularities, unsupported payments, or suspicious documentation. | Escalation record |
| 7 | Correct inaccurate records transparently | Correct inaccurate records transparently and preserve the original audit trail. | Corrected records and audit trail |
| 8 | Retain records per policy | Retain invoices, contracts, approvals, payment evidence and exception decisions under applicable retention rules — records must be retained for at least the period required by applicable law or internal policy, and longer where there is litigation, investigation, audit, or regulatory need. | Retained records inventory |
Exceptions and Escalation
Payment shall be stopped where support, rationale, approval, payee identity or service evidence is insufficient. Suspected concealment or falsification is escalated under the ABC investigation procedure.
Records
- Invoice, contract and service evidence
- Payment, expense and reimbursement approvals
- Commission or fee rationale
- Exception and escalation records
- Corrective accounting and audit trail
Relationships
- Policy: POL-ABC-001 Anti-Bribery and Corruption Manual
- Process: PRC-FCI-001 Financial Crime and Integrity
- Control: CTRL-ABC-005 Ensure ABC Books Records and Payments 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 transaction and periodic exception review
History
- 2026-07-28: Enriched steps with the full books-and-records minimum control standards (section 13): falsification prohibition scope, documented payment approval workflows, off-book prohibition, commercially justifiable commissions, and retention period guidance.
- 2026-07-26: Created from sections 6 and 13 of the approved ABC Manual.