Objective
Ensure unresolved, material or externally escalated complaints are handled through authorized channels with complete and confidential records, in accordance with sections 10 (Internal Follow-Up and Reporting) and 12 (Escalation Process) of the approved Client Complaints Handling Manual.
Control Activity
Compliance assesses internal escalation and external referral needs for overdue, disputed, material, recurring or systemic complaints. Clients receive applicable CBCS, ombudsman, court or alternative dispute-resolution information. Regulatory and external communications are authorized, accurate, timely and preserved, subject to legal, confidentiality and anti-tipping-off restrictions.
Specifically, the control verifies that:
- If a complainant is dissatisfied with Bitkaya’s final response, they are informed of their external escalation options: the Central Bank of Curaçao and Sint Maarten (CBCS), the Ombudsman, the Court of Justice, or an Alternative Dispute Resolution (ADR) mechanism where applicable.
- Complainants are provided with relevant contact details for each external body.
- Bitkaya cooperates fully with any external investigation or review.
- Bitkaya implements any binding decisions or corrective measures.
- Complaints data is provided to the CBCS upon request, ensuring full regulatory transparency.
- Escalated complaints and recurring issues are reviewed at management level.
Evidence
- Expected evidence: Escalation decision and approval
- Expected evidence: Client escalation information including contact details for CBCS, Ombudsman, Court of Justice, and ADR mechanism
- Expected evidence: Cooperation records with external investigations or reviews
- Expected evidence: Regulatory or external correspondence, including CBCS data requests and responses
- Expected evidence: Legal and confidentiality review
- Expected evidence: Submission and response tracking, including binding decisions implemented
- Expected evidence: Management-level review of escalated complaints and recurring issues
- 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 escalated complaints and verify authority, completeness (CBCS/Ombudsman/Court/ADR contact details provided), cooperation with external investigations, binding decisions implemented, CBCS data provision, timeliness, confidentiality and closure
- Testing frequency: per escalation
Relationships
- Policy: POL-COMP-001 Client Complaints Handling Manual
- Process: PRC-CPO-001 Client Protection and Operations
- Procedure: PROC-COMP-006 Escalate Complaints and Cooperate With External Bodies
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 10, 12 (external escalation bodies, CBCS/Ombudsman/Court/ADR, cooperation, binding decisions, CBCS data provision).
- 2026-07-26: Normalized evidence metadata and separated design status from runtime effectiveness.
- 2026-07-26: Created from the approved COMP Manual.