Purpose
Receive, acknowledge, investigate, resolve, escalate, analyze and retain complaints concerning execution, delays, restrictions, onboarding, transactions, safeguarding and communications, consistent with the approved Market Conduct & Trading Compliance Manual v1.1 section 7.
Steps
| # | Action | Details | Evidence |
|---|---|---|---|
| 1 | Maintain accessible complaint channels and inform clients how to submit and escalate concerns | Clients must be informed of clear channels through which they can submit complaints, including email, online portals and dedicated customer service contacts | MCT 7.1 Accessibility |
| 2 | Record the complaint, affected service, receipt date, client, issue, ownership and confidentiality constraints | Client complaints concerning execution, delays, restrictions, onboarding outcomes, transaction handling, safeguarding or communications must be handled fairly, promptly and in accordance with the complaints framework | MCT 7 intro |
| 3 | Confirm receipt in writing within five business days | Complaints should be acknowledged promptly (e.g., within two business days) with confirmation of receipt and an outline of the next steps | MCT 7.1 Acknowledgment |
| 4 | Within two weeks, provide registration confirmation, assigned officer contact details, an indicative timeframe and escalation rights | Standard response timelines must be established (e.g., resolution within 30 days, unless extended due to complexity) and clients must be kept updated on progress | MCT 7.1 Response Timelines |
| 5 | Assign impartial review and investigate consistently using order, communication, safeguarding and related evidence | Each complaint will be handled objectively, without bias toward the company or the client; similar complaints must be treated consistently to ensure fairness across all cases; resolution processes must align with local and international consumer protection laws ensuring that clients receive equitable treatment and outcomes | MCT 7.2 |
| 6 | Coordinate sanctions, unusual-activity, legal and compliance matters without overriding restrictions or breaching anti-tipping-off duties | Where a complaint touches on sanctions, unusual activity review, internal compliance escalation or legal restrictions, the complaint process must remain coordinated with the relevant control function; complaint handling must not override legal, compliance or confidentiality obligations; responses must be accurate and clear but must not disclose information in a manner that breaches anti-tipping-off or other legal restrictions | MCT 7 intro |
| 7 | Resolve within 30 business days from acknowledgment; where delay is unavoidable, document and communicate the reason and revised timeline | ||
| 8 | Provide internal escalation and applicable CBCS, alternative dispute-resolution, ombudsman or court channels | Bitkaya will provide internal escalation procedures allowing unresolved complaints to be reviewed by senior management or the Compliance team; where internal resolution is insufficient, clients will be advised of alternative dispute resolution (ADR) mechanisms, ombudsman services or relevant regulatory complaint platforms; certain complaints may trigger mandatory reporting to regulators particularly if they involve misconduct, systemic issues or breaches of regulatory requirements | MCT 7.3 |
| 9 | Assess misconduct, systemic issues and regulatory-reporting obligations | MCT 7.3 Regulatory Obligations | |
| 10 | Record investigation, communications, outcome, redress, escalation and closure | Each complaint must be recorded with details of the issue, investigation steps, communications and resolution outcome | MCT 7.4 Documentation |
| 11 | Retain the complete complaint record for at least ten years after resolution and analyze trends for improvement | Records must be retained for at least five years, or longer if required by local regulation; complaint data will be regularly reviewed to identify trends, systemic risks and opportunities for process improvements; records must be made available to regulators upon request demonstrating compliance with complaint-handling obligations | MCT 7.4 |
Exceptions and Escalation
Legal, sanctions and confidentiality obligations take precedence over ordinary disclosure. Material, overdue, recurring or systemic complaints shall be escalated to Compliance, management and the Board.
Records
- Complaint intake and acknowledgement
- Investigation and supporting evidence
- Client updates and resolution
- Internal and external escalation
- Regulatory assessment
- Trend analysis and remediation
Relationships
- Policy: POL-MCT-001 Market Conduct and Trading Compliance Manual
- Process: PRC-CPO-001 Client Protection and Operations
- Control: CTRL-MCT-006 Ensure Market Conduct Complaints Are Handled Fairly
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: per complaint with periodic trend review
History
- 2026-07-26: Created from section 7 of the approved MCT Manual.
- 2026-07-26: Aligned complaint deadlines, response content and retention with the Board-approved COMP Manual.