Purpose
Maintain accountable, independent complaint governance and accessible, secure and accurate submission information, as mandated by sections 3 (Complaints Management Policy), 4 (Complaints Management Function), 5 (Complaint Submission Channels), 11 (Provision of Information) and 14 (Proportionality and Scalability) of the approved Client Complaints Handling Manual.
Policy Endorsement and Documentation
The policy is formally approved and endorsed by Bitkaya’s Senior Management. It is documented, regularly updated, and accessible to all staff members. It forms part of Bitkaya’s internal control framework and risk management system. Management reviews the effectiveness of the policy at least twice per year, ensuring alignment with CBCS requirements and evolving best practices.
Complaints Management Function
A designated Complaints Officer is responsible for overseeing all complaints-handling activities. Responsibilities include acknowledgment, investigation, resolution, escalation, reporting, and recordkeeping. Independence is safeguarded: complaints officers cannot investigate complaints related to their own work or decisions. Officers must possess adequate knowledge of Bitkaya’s services, regulatory environment, and demonstrate impartiality, professionalism, and strong communication skills.
Steps
| # | Action | Details | Evidence |
|---|---|---|---|
| 1 | Designate a competent Complaints Officer | Responsible for overseeing all complaints-handling activities, including acknowledgment, investigation, resolution, escalation, reporting, and recordkeeping. | Role appointment record |
| 2 | Verify officer competence | Must possess adequate knowledge of Bitkaya’s services, regulatory environment, and demonstrate impartiality, professionalism, and strong communication skills. | Competence assessment record |
| 3 | Safeguard officer independence | Prevent an officer from investigating a complaint concerning that officer’s own work or decisions. | Independence declaration and conflict check |
| 4 | Maintain the three approved submission channels | Email: complaints@bitkaya.com; Online Form: www.bitkaya.com/complaints; Postal Mail: Bitkaya Board of Directors, Julianaplein 36, Willemstad, Curaçao. Test their accessibility, user-friendliness, and security. | Channel inventory and accessibility/security test records |
| 5 | Ensure continuous channel accessibility | Channels must remain accessible, user-friendly, and secure at all times. | Channel monitoring log |
| 6 | Publish clear complaint information | Via brochures and client pamphlets, client contracts, and Bitkaya’s website. | Published information and approval record |
| 7 | Provide written information on the complaints procedure | Upon acknowledgment or request. | Information provision record |
| 8 | Ensure published information is accurate and understandable | Describe scope, expected information (full name, contact details, clear description, relevant dates and evidence), timeframes, and escalation options. | Published information review record |
| 9 | Train client-facing staff to recognize complaints | Recognize expressions of dissatisfaction as complaints regardless of whether the complainant uses the word “complaint.” | Training records |
| 10 | Review governance, channels, and published information | At least semi-annually and after material change, ensuring alignment with CBCS requirements and evolving best practices. | Semi-annual review minutes |
| 11 | Apply the proportionality principle | A single designated Complaints Officer fulfills the complaints management function; this role may be combined with other compliance-related duties, provided independence and impartiality are maintained. | Proportionality assessment record |
Records
- Role appointment and independence safeguards
- Approved channels (email, online form, postal mail) and channel accessibility/security tests
- Published complaint information (brochures, client contracts, website) and approvals
- Staff guidance, training, and semi-annual policy effectiveness review
- Proportionality assessment of governance structure
Relationships
- Policy: POL-COMP-001 Client Complaints Handling Manual
- Process: PRC-CPO-001 Client Protection and Operations
- Control: CTRL-COMP-001 Ensure Complaints Governance Channels and Information Are Current
History
- 2026-07-28: Enriched with full operational details from PDF sections 3, 4, 5, 11, 14 (policy endorsement, management function, channels, provision of information, proportionality).
- 2026-07-26: Created from sections 3-5, 11 and 14 of the approved COMP Manual.