Objective
Ensure ABC responsibilities, resources, risk assessment, treatment and Board oversight remain current and proportionate.
Control Activity
Compliance maintains the ABC EWRA and coordinates annual and event-driven review of corruption exposure, controls, residual risk, treatment actions and resources. Management and the Board review material risk, incidents, control effectiveness and overdue remediation. The Board shall approve this manual and any material updates, review Bitkaya’s ABC risk profile at least annually, receive periodic reporting on ABC incidents, control effectiveness, and remediation, and challenge management on the adequacy of resources, controls, and oversight. Executive Management ensures appropriate resources, staffing, and internal coordination, supports escalation, investigation, and remediation, embeds ethical conduct into business planning, incentives, growth initiatives, and third-party relationships, and ensures that commercial pressure does not override ABC controls. The Compliance Officer or designated ABC Officer maintains the ABC framework and procedures, advises business units on ABC risks, reviews escalations and higher-risk arrangements, coordinates management and Board reporting, supports investigations, coordinates training, testing, and remediation tracking, and maintains the ABC EWRA.
Evidence
- Expected evidence: Approved ABC EWRA and methodology
- Expected evidence: Risk treatment and acceptance records
- Expected evidence: Responsibility and resource assessment
- Expected evidence: Management and Board reporting or minutes
- Expected evidence: Remediation tracker
- Evidence location: source evidence in SYS-ECM-001 Compliance Framework Library, SYS-ECM-002 Compliance Reporting and Evidence Repository; target Hermes assessment record in Odoo under ISS-HERMES-001.
- Retention: according to the applicable approved policy and Bitkaya record-retention requirements.
- Testing method: inspect annual approval and sample material risks through treatment, escalation and closure
- Testing frequency: annual and after material change
Relationships
- Requirements: REQ-VASP-003 Maintain Governance and Fit and Proper Oversight, REQ-VASP-005 Maintain Integrity Based Business Operations
- Policy: POL-ABC-001 Anti-Bribery and Corruption Manual
- Process: PRC-FCI-001 Financial Crime and Integrity
- Procedure: PROC-ABC-001 Govern ABC and Maintain the Enterprise-Wide Risk Assessment
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.
- Design status: implemented
History
- 2026-07-28: Enriched control activity with the full Board, Executive Management and Compliance Officer responsibility lists from section 4 of the approved ABC Manual.
- 2026-07-26: Normalized evidence metadata and separated design status from runtime effectiveness.
- 2026-07-26: Created from the approved ABC Manual version 1.0.