Purpose
Ensure advertising, promotions, client communications, disclosures and social-media activity are accurate, balanced, approved and legally compliant, consistent with the approved Market Conduct & Trading Compliance Manual v1.1 sections 2.3, 3.3 and 5.
This procedure operates through the detailed COMM workflow and remains the market-conduct interface for communication risk.
Steps
| # | Action | Details | Evidence |
|---|---|---|---|
| 1 | Submit all marketing and promotional material to Compliance before release | Promotional materials must undergo Compliance review and approval before release to ensure accuracy and compliance | MCT 5.1 Review Process |
| 2 | Verify factual accuracy, balance, substantiation, risks, fees, limitations, target jurisdiction and applicable consumer or financial-promotion requirements | All advertising must be factual, balanced and capable of substantiation; claims of performance or benefits must be supported by verifiable data (MCT 5.1 Accuracy and Balance); all communications must comply with applicable securities, consumer protection and financial promotion regulations in the jurisdictions where they are published | MCT 5.1 Regulatory Compliance |
| 3 | Prohibit exaggeration, material omission, speculative claims and guarantees of return | Marketing must avoid exaggerations, omissions or promises of guaranteed returns as these are misleading and non-compliant with financial promotion regulations (MCT 5.1 No Misleading Statements); employees must not provide false, misleading or exaggerated statements about Bitkaya’s services, the risks of digital assets or potential returns; misrepresentation may also occur through omission such as failing to disclose significant risks, fees or limitations | MCT 3.3 |
| 4 | Use approved language for order, trade, execution, delay, restriction, safeguarding and service-availability communications | Communications relating to trades, execution, delays, restrictions or service availability must be fair, accurate and consistent with Bitkaya’s legal and regulatory obligations | MCT 5.2 |
| 5 | Protect confidential information and avoid explaining or implying internal sanctions, unusual-activity or compliance conclusions where that would breach anti-tipping-off or other restrictions | Where a transaction, withdrawal, settlement or onboarding step is delayed or cannot proceed because of legal, sanctions, safeguarding or compliance concerns, communication must be handled carefully and in accordance with applicable confidentiality and anti-tipping-off restrictions; staff must not explain, confirm or imply internal compliance conclusions in a way that would breach legal restrictions or compromise an ongoing review | MCT 5.2 |
| 6 | Restrict official social-media statements to authorized spokespersons and prohibit employees from presenting personal views as Bitkaya positions | Only designated and authorized employees may make official statements on behalf of Bitkaya via social platforms; employees must not use personal accounts to make statements that could be construed as representing Bitkaya’s official views, services or positions | MCT 5.3 Authorized Spokespersons, Personal Use |
| 7 | Prohibit sharing confidential information, speculative claims or unverified statements about Bitkaya or the digital asset market | MCT 5.3 Prohibited Content | |
| 8 | Monitor public communications proportionately for misleading, confidential, speculative or reputationally harmful content | Bitkaya reserves the right to monitor public communications for potential reputational or regulatory risks and will take action where necessary | MCT 5.3 Monitoring |
| 9 | Retain the submitted version, substantiation, review comments, approval, publication and correction history |
Exceptions and Escalation
No promotion may be released without required Compliance approval. Unclear jurisdictional, licensing, confidentiality or disclosure issues shall be escalated before communication.
Records
- Proposed and approved communication
- Claims substantiation and risk disclosure
- Compliance review and approval
- Publication or distribution evidence
- Correction, withdrawal or escalation record
Relationships
- Policy: POL-MCT-001 Market Conduct and Trading Compliance Manual
- Process: PRC-CPO-001 Client Protection and Operations
- Control: CTRL-MCT-004 Ensure Market Communications Are Accurate and Approved
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: before publication and on identified communication risk
History
- 2026-07-26: Created from sections 2.3, 3.3 and 5 of the approved MCT Manual.
- 2026-07-26: Linked to the dedicated COMM operating framework and licensing-representation issue.