Purpose
Maintain Board oversight, cross-functional governance and accountable execution of Bitkaya’s ESG objectives, ensuring accountability and effective implementation of the ESG governance framework.
Steps
| # | Action | Details | Evidence |
|---|---|---|---|
| 1 | Propose annual ESG objectives | Material topics, KPIs, risk tolerances and accountable owners, aligned with the company’s strategic objectives. | Approved ESG objectives and responsibility matrix |
| 2 | Obtain Board approval for strategy, policy and material ESG initiatives | The Board of Directors provides oversight and approves ESG strategies, policies, and key initiatives, ensuring ESG matters are aligned with the company’s strategic objectives. | Board papers, decisions and escalations |
| 3 | Convene the ESG Committee at least quarterly | Cross-functional leaders from Compliance, Finance, Operations and Human Resources. The ESG Committee is responsible for ESG implementation, monitoring progress, and reporting outcomes. It meets quarterly to review ESG KPIs, risks, and stakeholder concerns. | Committee agenda, papers, minutes and attendance |
| 4 | Review KPI results, material risks, incidents, stakeholder concerns, overdue actions and required decisions | — | KPI report, risk summary and action log |
| 5 | Assign actions, deadlines and escalation levels and track them to closure | — | Action log |
| 6 | Escalate material ethical, environmental, social, legal or reputational matters promptly | — | Board papers, decisions and escalations |
| 7 | Report performance and unresolved material matters to the Board | — | Board papers, decisions and escalations |
Roles and Responsibilities
- Board of Directors: Provides oversight and approves ESG strategies, policies, and key initiatives. Ensures ESG matters are aligned with the company’s strategic objectives.
- ESG Committee: Composed of cross-functional leaders from compliance, finance, operations, and HR. Responsible for ESG implementation, monitoring progress, and reporting outcomes. Meets quarterly to review ESG KPIs, risks, and stakeholder concerns.
- Compliance & Risk Function: Ensures ESG principles are embedded into risk management and regulatory compliance processes. Monitors adherence to anti-corruption, AML/CFT, and ethical standards.
Proportionality Considerations
- In Bitkaya’s early stage, ESG responsibilities are combined within existing compliance and operations roles. As the company expands, a dedicated ESG function will be formalized to manage sustainability reporting and stakeholder engagement.
- The Management Board provides strategic oversight, ensures alignment between ESG goals and corporate objectives, and maintains a strong ethical tone at the top.
- The Compliance Officer integrates proportionality into compliance and governance processes, oversees ethical and ESG reporting, and monitors adherence to internal and regulatory standards.
Records
- Approved ESG objectives and responsibility matrix
- Committee agenda, papers, minutes and attendance
- KPI report, risk summary and action log
- Board papers, decisions and escalations
Relationships
- Policy: POL-ESG-001 Governance Ethics and ESG Manual
- Process: PRC-GRO-001 Governance Risk and Outsourcing
- Control: CTRL-ESG-001 Ensure ESG Governance Strategy and Oversight Are Current
History
- 2026-07-26: Created from section 2 of the approved ESG Manual.