Objective
Ensure every expression of dissatisfaction is recognized, securely registered and acknowledged within the approved service levels, in accordance with sections 1 (Purpose and Scope), 2 (Definitions), 5 (Complaint Submission Channels), 6 (Acknowledgment of Complaints) and 7 (Complaints Register and Recordkeeping) of the approved Client Complaints Handling Manual.
Control Activity
The complaint owner records every complaint in the centralized, secure electronic register, assigns a unique reference and confirms receipt in writing within 5 business days. Within 2 weeks, the complainant receives registration confirmation, the assigned officer’s contact details, an indicative timeframe for investigation and resolution, and information about escalation rights. Overdue or incomplete records are escalated to Compliance.
Specifically, the control verifies that:
- Any expression of dissatisfaction — whether justified or not, and whether or not the complainant uses the word “complaint” — is recognized as a complaint. Examples include service delays, product malfunctions, regulatory or contractual concerns, staff misconduct, or allegations of unfair treatment.
- Complaints received from clients, business partners, investors, or other stakeholders concerning products/services, staff conduct, regulatory compliance, contractual obligations, or ethical standards are within scope.
- Complaints may be submitted orally, in writing, or electronically, and all complaints regardless of form are logged and addressed.
- The centralized, secure electronic register includes: complainant details, date of receipt, description and potential impact, status (open, under investigation, resolved), and resolution details and final response date.
- The complainant receives written acknowledgment within 5 business days.
- Within 2 weeks, the complainant receives: confirmation of complaint registration, contact details of the assigned Complaints Officer, and an indicative timeframe for investigation and resolution.
- The complainant is informed of their rights, including escalation options if dissatisfied.
- All complaints data is retained for at least 10 years after resolution.
Evidence
- Expected evidence: Centralized, secure electronic complaint register with: complainant details, date of receipt, description and potential impact, status (open, under investigation, resolved), and resolution details and final response date
- Expected evidence: Original complaint and attachments
- Expected evidence: Written acknowledgment delivered within 5 business days
- Expected evidence: Two-week registration communication (registration confirmation, assigned officer contact details, indicative timeframe, escalation rights)
- Expected evidence: Exception and overdue-case report
- Expected evidence: Retention confirmation (minimum 10 years after resolution)
- 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 complaints and recalculate the 5-business-day acknowledgment deadline and 2-week registration communication deadline from source records; verify register fields completeness; confirm 10-year retention
- Testing frequency: per complaint with at least monthly overdue-case review
Relationships
- Policy: POL-COMP-001 Client Complaints Handling Manual
- Process: PRC-CPO-001 Client Protection and Operations
- Procedure: PROC-COMP-002 Receive Register and Acknowledge Complaints
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 1, 2, 5, 6, 7 (definitions, scope, channels, acknowledgment timelines, register fields, 10-year retention).
- 2026-07-26: Normalized evidence metadata and separated design status from runtime effectiveness.
- 2026-07-26: Created from the approved COMP Manual.