Purpose
Produce evidence-based ESG reporting and ensure governance remains proportionate to Bitkaya’s scale, complexity and risk, disclosing ESG performance through an annual sustainability statement aligned with recognized frameworks (e.g., GRI, SASB).
Steps
| # | Action | Details | Evidence |
|---|---|---|---|
| 1 | Define the annual reporting scope, metrics, owners, methodology, boundary and evidence requirements | Include ESG summaries in annual governance statements. | Metric definitions, source data and reconciliations |
| 2 | Collect and reconcile approved environmental, social, ethics, governance, risk and community data | All proportionality measures are documented, reviewed, and updated to ensure transparency and traceability. Records include ESG meeting notes, policy updates, training logs, and compliance reviews. | ESG meeting notes, policy updates, training logs, and compliance reviews |
| 3 | Investigate material variances and validate narrative statements and claims against evidence | — | Drafts, review comments, approvals and final reporting |
| 4 | Prepare an annual sustainability statement using relevant GRI or SASB concepts where proportionate | Transition to full sustainability reporting (aligned with GRI/SASB frameworks) as regulatory scope and operations expand. | Drafts, review comments, approvals and final reporting |
| 5 | Obtain Compliance, management and Board review before external use | Disclose ESG performance through the annual sustainability statement. | Drafts, review comments, approvals and final reporting |
| 6 | Complete an annual proportionality assessment, led by the Compliance Officer | Evaluating whether governance, ethics, and ESG measures remain appropriate to Bitkaya’s operational profile. Findings are reported to the Management Board for approval and implementation of any required enhancements. Assess proportionality annually and after material change, considering scale, complexity, risk, stakeholders and regulatory expectations. | Annual proportionality assessment with Management Board approval |
| 7 | Record policy, training, tooling, resource, governance and assurance improvements and track them to closure | Progressively strengthen ESG governance through gradual enhancement of systems and reporting frameworks, integration of ESG data tools and automation, benchmarking against international ESG standards and peer practices, and periodic independent assessments of ESG maturity and proportionality adequacy. | Improvement plan, policy updates and training records; benchmarking and independent assessment results |
Proportionality Considerations
- The proportionality framework is reviewed annually, or upon material changes, to ensure continued alignment with regulatory expectations, operational realities, and stakeholder needs.
- Include ESG summaries in annual governance statements. Transition to full sustainability reporting as regulatory scope and operations expand.
- This approach aligns with supervisory expectations under the Central Bank of Curaçao and Sint Maarten (CBCS), the National Ordinance on the Supervision of Virtual Asset Service Providers (NOSVASP), and international ESG best practices.
Records
- Metric definitions, source data and reconciliations
- ESG meeting notes, policy updates, training logs, and compliance reviews
- Drafts, review comments, approvals and final reporting
- Annual proportionality assessment with Management Board approval
- Improvement plan, policy updates and training records
- Benchmarking and independent assessment results
Relationships
- Policy: POL-ESG-001 Governance Ethics and ESG Manual
- Process: PRC-GRO-001 Governance Risk and Outsourcing
- Control: CTRL-ESG-007 Ensure ESG Reporting Proportionality and Improvement Are Current
History
- 2026-07-26: Created from sections 4.3 and 5 of the approved ESG Manual.