Purpose
Maintain annual employee ethics accountability and ensure the handbook remains current, proportionate and effective.
Steps
| # | Action | Details | Evidence |
|---|---|---|---|
| 1 | Obtain annual ethics certification | Obtain an annual certification from each in-scope person confirming policy awareness, compliance, conflict disclosure and reporting of known concerns; everyone must certify compliance with the Code of Ethics annually. | Ethics certification |
| 2 | Follow up incomplete or inconsistent certifications | Follow up incomplete, qualified or inconsistent certifications and escalate material matters; breaches can result in disciplinary action, termination, and regulatory reporting. | Follow-up record |
| 3 | Review compliance data for trends | Review acknowledgment, training, conflict, whistleblowing, disciplinary, audit and remediation data for trends. | Trend analysis |
| 4 | Assess proportionality | Assess whether roles, resources, automation, monitoring and controls remain proportionate to Bitkaya size, complexity, products and risks, considering: right-sized controls suitable for a small company but scalable for growth (e.g., a single Compliance Officer overseeing multiple control areas, supported by automated systems and external advisors); scalable frameworks reviewed periodically to ensure they evolve with business expansion, technological changes, or new regulatory requirements; practical resource allocation with clearly defined responsibilities maintaining accountability at all levels; and technology leverage using automated tools and cloud-based systems to ensure consistency, reduce manual errors, and maintain efficient oversight without excessive cost. | Proportionality assessment |
| 5 | Identify changes affecting the handbook | Identify legal, regulatory, organizational, technology and policy changes affecting the handbook, including changes to Curacao Landsverordening toezicht virtuele activa dienstverleners and supervisory expectations under the CBCS. | Change identification record |
| 6 | Draft amendments and obtain Board approval | Draft amendments, complete stakeholder review and obtain Board approval for material changes. | Amendment and approval record |
| 7 | Publish controlled version | Publish the controlled version, archive superseded versions and trigger communication, training and renewed acknowledgment where needed. | Version publication record |
| 8 | Report annual review to management and Board | Report the annual review, open actions and material concerns to management and the Board. | Review report |
Exceptions and Escalation
Material gaps shall not wait for the annual cycle. Compliance shall initiate an interim review and escalate urgent changes or unresolved certification concerns.
Records
- Annual ethics certifications
- Trend and effectiveness analysis
- Proportionality assessment
- Review and approval record
- Version, communication, training and acknowledgment evidence
Relationships
- Policy: POL-EMP-001 Employee Handbook
- Process: PRC-RSA-001 Resilience Systems and Assurance
- Control: CTRL-EMP-007 Ensure Ethics Certification and Handbook Review Are Current
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: annual and after material change
History
- 2026-07-26: Created from sections 4, 7 and 8 of the approved Employee Handbook.