Objective
Ensure elevated corruption risks involving public-sector parties, contributions and personal conflicts receive documented review, approval and restriction.
Control Activity
Compliance reviews public-official and state-linked interactions, donations, sponsorships, political contributions and disclosed conflicts. For interactions involving public officials, regulators, supervisors, tax authorities, law enforcement, licensing authorities, or state-owned entities, the review confirms a legitimate business purpose for each interaction, appropriate documentation of material meetings or requests, enhanced review of gifts, travel, hospitality, reimbursements, or benefits involving public officials, and immediate escalation of any request for unofficial payments, favors, expedited treatment, or off-record arrangements. Under no circumstances may Bitkaya provide anything of value to obtain or retain business improperly, influence a regulatory outcome, avoid a penalty, or secure preferential treatment. For donations and sponsorships, the review confirms the recipient is legitimate and verifiable, the purpose is documented, there is no link to an improper advantage, the payment is appropriately approved, and the donation or sponsorship is accurately recorded. Political contributions on behalf of the company are prohibited unless expressly approved by the Board and permitted by applicable law; no political contribution may be used to influence regulatory treatment or obtain a business advantage. For conflicts of interest, the review confirms disclosure of outside business interests, financial interests in vendors, service providers, or counterparties, family or personal relationships with decision-makers or public officials, and personal benefits linked to company transactions, and applies proportionate disclosure, escalation, restriction, or prohibition measures.
Evidence
- Expected evidence: Sensitive-interaction purpose and approval
- Expected evidence: Donation or sponsorship verification and approval
- Expected evidence: Board approval for any legally permitted political contribution
- Expected evidence: Conflict disclosure, assessment and treatment
- Expected evidence: Escalation and monitoring evidence
- Evidence location: source evidence in 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: sample sensitive interactions and disclosures for complete review, approval, accounting and treatment
- Testing frequency: per event and periodic conflict review
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-004 Manage Sensitive Interactions Contributions and Conflicts
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 public-official minimum requirements (section 10), donation permissibility conditions (section 11), political-contribution restriction (section 11), and conflict-disclosure categories and management measures (section 12).
- 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.