Purpose
Receive, protect, assess, investigate, remediate and report suspected bribery, corruption, financial irregularity or ABC-control circumvention.
Steps
| # | Action | Details | Evidence |
|---|---|---|---|
| 1 | Accept reports through channels | Accept reports through line management, Compliance, HR or designated whistleblower channels. | Report intake record |
| 2 | Record and protect reporter | Record the concern securely, restrict access and protect the reporter from retaliation. Retaliation against any person who raises a good-faith concern regarding suspected bribery or corruption is strictly prohibited. | Secure allegation record |
| 3 | Triage the concern | Triage credibility, severity, immediacy, conflicts, evidence-preservation needs and legal or regulatory implications. | Triage assessment |
| 4 | Assign independent investigator | Assign an appropriately independent investigator and documented scope. | Investigation scope and assignment |
| 5 | Preserve relevant evidence | Preserve relevant communications, contracts, payment records, system evidence and witness information. | Evidence preservation record |
| 6 | Conduct documented investigation | Conduct a timely, fair, risk-sensitive and documented investigation. | Investigation findings |
| 7 | Escalate material matters | Escalate material matters to management and the Board while preserving confidentiality. | Management and Board escalation record |
| 8 | Determine remedial actions | Determine disciplinary, contractual, recovery, regulatory, authority or law-enforcement action with appropriate advice. Breaches may result in disciplinary action up to and including termination of employment or contract. Bitkaya may also terminate third-party relationships, report matters to regulators or competent authorities, refer matters to law enforcement, and seek recovery of losses or other legal remedies. The severity of response shall reflect the seriousness of the conduct, management responsibility, intent, harm caused, and cooperation during investigation. | Decision and action record |
| 9 | Assign root-cause remediation | Assign root-cause and control-remediation actions, owners and due dates. | Remediation plan |
| 10 | Close after documentation approved | Close only after findings, decisions, notifications and remediation are documented and approved. | Closure approval record |
Exceptions and Escalation
Any conflict involving management, Compliance or the normal investigator requires independent escalation. An immediate health or safety facilitation-payment event must be reported immediately afterward.
Records
- Secure allegation and triage record
- Investigation scope, evidence and findings
- Non-retaliation and confidentiality controls
- Management and Board escalation
- Disciplinary, contractual or external-reporting decision
- Remediation and closure evidence
Relationships
- Policy: POL-ABC-001 Anti-Bribery and Corruption Manual
- Process: PRC-FCI-001 Financial Crime and Integrity
- Control: CTRL-ABC-006 Ensure ABC Concerns Are Escalated and Investigated
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 concern or identified red flag
History
- 2026-07-28: Enriched steps with the full red-flag list (section 14), non-retaliation prohibition, and disciplinary/external-reporting options (section 19).
- 2026-07-26: Created from sections 3, 6, 14 and 19 of the approved ABC Manual.