Purpose
Assess complaint urgency, risk, scope and conflicts and assign an impartial investigator with appropriate competence, as mandated by sections 2 (Definitions), 4 (Complaints Management Function) and 8 (Investigation Process) of the approved Client Complaints Handling Manual.
Independence Safeguard
The Complaints Management Function requires that 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 | Classify the complaint by category | Product/service, staff conduct/professionalism/behavior, regulatory compliance and contractual obligations, or ethical standards/fairness in dealing — matching the scope defined in section 1 of the manual. | Classification record |
| 2 | Assess severity and impact | Client harm, financial impact, vulnerable-client factors, recurrence and potential systemic impact. | Risk triage record |
| 3 | Identify related considerations | Related incidents, suspicious activity, litigation, privacy, security, safeguarding or regulatory-reporting considerations. | Related-matter assessment |
| 4 | Escalate urgent or high-risk matters | Promptly without waiting for ordinary review milestones. | Escalation log entry |
| 5 | Check investigator independence | Confirm the proposed investigator did not participate in the conduct, work, or decision complained about — complaints officers cannot investigate complaints related to their own work or decisions. | Independence / conflict check |
| 6 | Assign an independent officer | Must possess adequate knowledge of Bitkaya’s services, regulatory environment, and demonstrate impartiality, professionalism, and strong communication skills. Provide relevant subject-matter support. | Assignment record |
| 7 | Define investigation scope | Evidence needs, target date, and reporting level consistent with the requirement for an impartial and thorough investigation. | Investigation plan |
| 8 | Update the centralized register and notify the complainant | If the indicative timeline materially changes. | Register update and timeline notice |
Records
- Classification and risk triage (by product/service, conduct, regulatory, contractual, ethical, or fairness category)
- Conflict and independence check (confirming officer did not participate in the complained-about work or decision)
- Assignment and investigation plan (with competence and impartiality confirmation)
- Escalation and revised-timeline evidence
Relationships
- Policy: POL-COMP-001 Client Complaints Handling Manual
- Process: PRC-CPO-001 Client Protection and Operations
- Control: CTRL-COMP-003 Ensure Complaints Are Risk Triaged and Assigned Impartially
History
- 2026-07-28: Enriched with full operational details from PDF sections 2, 4, 8 (definitions, independence safeguard, officer competence requirements).
- 2026-07-26: Created from sections 2, 4 and 8 of the approved COMP Manual.