Objective
Ensure complaints are risk-classified, assigned to a competent independent officer and escalated where they indicate material or systemic risk, in accordance with sections 2 (Definitions), 4 (Complaints Management Function) and 8 (Investigation Process) of the approved Client Complaints Handling Manual.
Control Activity
For each complaint, the complaint owner documents severity, urgency, client impact, regulatory implications, vulnerability and potential systemic significance. The assigned investigator confirms independence and must not investigate their own work or decision. Conflicts, high-risk matters and possible misconduct or reporting obligations are escalated to Compliance and management.
Specifically, the control verifies that:
- Complaints are classified by the scope categories defined in the manual: products and services, staff conduct/professionalism/behavior, regulatory compliance and contractual obligations, and ethical standards or fairness in dealing.
- The proposed investigator did not participate in the conduct, work, or decision complained about — complaints officers cannot investigate complaints related to their own work or decisions.
- The assigned officer possesses adequate knowledge of Bitkaya’s services, regulatory environment, and demonstrates impartiality, professionalism, and strong communication skills.
- Urgent or high-risk matters are escalated promptly without waiting for ordinary review milestones.
- The investigation scope, evidence needs, target date, and reporting level are defined consistent with the requirement for an impartial and thorough investigation.
- The register is updated and the complainant is notified if the indicative timeline materially changes.
Evidence
- Expected evidence: Complaint classification by manual scope category (products/services, staff conduct, regulatory/contractual, ethical/fairness)
- Expected evidence: Investigator assignment and conflict declaration confirming the officer did not participate in the complained-about work or decision
- Expected evidence: Officer competence documentation (knowledge of services, regulatory environment, impartiality, professionalism, communication skills)
- Expected evidence: Materiality and regulatory-reporting assessment
- Expected evidence: Escalation and reassignment records
- Expected evidence: Updated register and revised-timeline notification to complainant
- 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 complaint assignments and verify classification by manual scope category, officer competence, independence (officer did not investigate own work/decision), impartiality, and escalation decisions
- Testing frequency: per complaint
Relationships
- Policy: POL-COMP-001 Client Complaints Handling Manual
- Process: PRC-CPO-001 Client Protection and Operations
- Procedure: PROC-COMP-003 Triage Classify and Assign Complaints Impartially
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 2, 4, 8 (definitions, independence safeguard, officer competence requirements).
- 2026-07-26: Normalized evidence metadata and separated design status from runtime effectiveness.
- 2026-07-26: Created from the approved COMP Manual.