Purpose
Ensure suspected handbook violations receive fair, consistent, proportionate and documented resolution.
Steps
| # | Action | Details | Evidence |
|---|---|---|---|
| 1 | Receive substantiated finding or conduct concern | Receive a substantiated finding or other documented conduct concern and protect relevant evidence. | Finding and evidence record |
| 2 | Confirm facts and applicable policy | Confirm the facts, applicable policy, employee response, prior related events, impact and legal or regulatory implications. | Case confirmation |
| 3 | Classify the matter | Classify as Minor Mistakes (e.g., missing a training deadline, forgetting to update a compliance form, or minor administrative oversights — handled as opportunities for learning and improvement but documented), Serious Violations (e.g., failing to follow AML/CFT procedures, ignoring cybersecurity protocols, mishandling confidential client data, or failing to disclose conflicts of interest), or Gross Misconduct (e.g., insider trading, fraud, bribery, market manipulation, theft, or misusing client funds). | Classification record |
| 4 | Handle minor matters | Consider verbal or written warnings, mandatory retraining, closer supervision or corrective guidance. | Minor matter resolution |
| 5 | Handle serious matters | Consider formal disciplinary action including suspension, demotion, reassignment or termination of employment; such cases may also be reported to regulators depending on severity. | Serious matter decision |
| 6 | Handle gross misconduct | Escalate immediately for dismissal and possible criminal prosecution, civil penalties, or regulatory enforcement actions; Bitkaya will cooperate fully with law enforcement and regulators. | Gross misconduct escalation |
| 7 | Check consistency and obtain approval | Check consistency with comparable cases and obtain appropriate Human Resources, Compliance, management, Board or legal approval; document personal and company liability considerations, including potential fines, bans from working in financial services, or imprisonment for the individual and heavy fines, sanctions, reputational damage, or loss of licenses for the company. | Approval and consistency record |
| 8 | Communicate decision and monitor remediation | Communicate the decision, preserve confidentiality, record actions and monitor remediation. | Decision and remediation record |
Exceptions and Escalation
Urgent protective measures may be taken before final resolution where clients, evidence, systems, assets or personnel are at risk. Such measures and their basis shall be documented and reviewed promptly.
Records
- Finding and evidence record
- Classification and proportionality assessment
- Employee response and decision approvals
- Disciplinary and remediation evidence
- Regulatory or legal escalation records
Relationships
- Policy: POL-EMP-001 Employee Handbook
- Process: PRC-RSA-001 Resilience Systems and Assurance
- Procedure: PROC-EMP-004 Receive and Investigate Whistleblower Reports
- Control: CTRL-EMP-005 Ensure Employee Violations Receive Consistent Disciplinary Action
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: event-driven
History
- 2026-07-26: Created from sections 3 and 6 of the approved Employee Handbook.