Objective
Ensure credible ABC concerns are protected, assessed, independently investigated, reported and remediated.
Control Activity
Compliance maintains secure intake and triage for ABC concerns, protects good-faith reporters — retaliation against any person who raises a good-faith concern regarding suspected bribery or corruption is strictly prohibited — assigns conflict-free investigation responsibility, preserves evidence and tracks findings, decisions, external reporting and remediation to approved closure. Red flags to watch for include requests for unusual commissions or success fees, pressure to use a specific consultant without a clear rationale, invoices lacking sufficient detail, requests to pay through unrelated entities or offshore accounts without justification, offers of gifts or favors during a decision-making process, suggestions to keep arrangements informal, off-record, or undocumented, and requests by a public official, intermediary, or counterparty for a personal favor or unofficial payment. Breaches may result in disciplinary action up to and including termination of employment or contract; Bitkaya may also terminate third-party relationships, report matters to regulators or competent authorities, refer matters to law enforcement, and seek recovery of losses or other legal remedies. The severity of response reflects the seriousness of the conduct, management responsibility, intent, harm caused, and cooperation during investigation.
Evidence
- Expected evidence: Secure concern and triage record
- Expected evidence: Investigator independence and scope
- Expected evidence: Preserved evidence and investigation findings
- Expected evidence: Management and Board escalation
- Expected evidence: Disciplinary, contractual or external-reporting decision
- Expected evidence: Remediation and closure 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 closed and open matters for timely triage, confidentiality, independence, evidence, escalation and remediation
- Testing frequency: per concern with periodic case-file review
Relationships
- Requirements: REQ-VASP-005 Maintain Integrity Based Business Operations, REQ-VASP-014 Cooperate With CBCS Supervision and Enforcement
- Policy: POL-ABC-001 Anti-Bribery and Corruption Manual
- Process: PRC-FCI-001 Financial Crime and Integrity
- Procedure: PROC-ABC-006 Handle ABC Speak-Up Escalation and Investigations
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 red-flag list (section 14), non-retaliation prohibition (section 3), and disciplinary/external-reporting options and severity factors (section 19).
- 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.