Objective
Ensure complaint ownership, channels, client information and governance arrangements remain accessible, current and approved, in accordance with sections 3 (Complaints Management Policy), 4 (Complaints Management Function), 5 (Complaint Submission Channels), 11 (Provision of Information) and 14 (Proportionality and Scalability) of the approved Client Complaints Handling Manual.
Control Activity
Compliance reviews the complaints framework at least semiannually and after material change. The review confirms accountable ownership, designated complaint-handling responsibility, accessible intake channels, published client instructions, escalation routes, confidentiality safeguards and consistency across the approved manual, website and operating tools.
Specifically, the control verifies that:
- The policy is formally approved and endorsed by Bitkaya’s Senior Management, documented, regularly updated, and accessible to all staff members.
- The policy forms part of Bitkaya’s internal control framework and risk management system.
- Management reviews the effectiveness of the policy at least twice per year, ensuring alignment with CBCS requirements and evolving best practices.
- A designated Complaints Officer is responsible for overseeing all complaints-handling activities, with defined responsibilities including acknowledgment, investigation, resolution, escalation, reporting, and recordkeeping.
- Independence is safeguarded: complaints officers cannot investigate complaints related to their own work or decisions.
- Officers possess adequate knowledge of Bitkaya’s services, regulatory environment, and demonstrate impartiality, professionalism, and strong communication skills.
- The three approved submission channels remain accessible, user-friendly, and secure: Email (complaints@bitkaya.com), Online Form (www.bitkaya.com/complaints), Postal Mail (Bitkaya Board of Directors, Julianaplein 36, Willemstad, Curaçao).
- Complainants are informed of the expected submission information: full name and contact details, clear description of the complaint, and relevant dates, documentation, or evidence.
- Written information on the complaints procedure is provided upon acknowledgment or request, and published via brochures and client pamphlets, client contracts, and Bitkaya’s website.
- All published information is accurate, up-to-date, and easy to understand.
- The proportionality principle is applied: a single designated Complaints Officer fulfills the complaints management function, which may be combined with other compliance-related duties, provided independence and impartiality are maintained.
Evidence
- Expected evidence: Approved complaints manual and ownership record
- Expected evidence: Channel availability and test results for all three approved channels (email, online form, postal mail)
- Expected evidence: Published client complaint and escalation information (brochures, client contracts, website)
- Expected evidence: Semiannual governance review and remediation record, confirming policy effectiveness review and alignment with CBCS requirements
- Expected evidence: Complaints Officer competence and independence documentation
- Expected evidence: Proportionality assessment of governance structure
- 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: inspect governance approval, test each published channel (email, online form, postal mail) for accessibility and security, compare all published details with the approved manual, verify officer competence and independence safeguards, confirm semiannual policy effectiveness review
- Testing frequency: semiannual and after material change
Relationships
- Policy: POL-COMP-001 Client Complaints Handling Manual
- Process: PRC-CPO-001 Client Protection and Operations
- Procedure: PROC-COMP-001 Govern Complaints Function Channels and Information
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 verification requirements with full details from PDF sections 3, 4, 5, 11, 14 (policy endorsement, management function, channels, provision of information, proportionality).
- 2026-07-26: Normalized evidence metadata and separated design status from runtime effectiveness.
- 2026-07-26: Created from the approved COMP Manual.