Objective
Ensure complaint experience is analyzed and reported, recurring causes are remediated, staff remain competent and the framework improves, in accordance with sections 10 (Internal Follow-Up and Reporting), 13 (Continuous Improvement) and 14 (Proportionality and Scalability) of the approved Client Complaints Handling Manual.
Control Activity
At least semiannually, Compliance analyzes complaint volumes, categories, aging, outcomes, redress, recurrence, root causes and control implications. Management reviews the analysis, records decisions and assigns corrective actions. Relevant staff receive role-based complaint training, and the complaints framework is reviewed after material incidents, legal change or recurring weaknesses.
Specifically, the control verifies that:
- Complaints data is regularly analyzed to identify root causes, trends, and systemic issues.
- Senior management reviews findings at least every 6 months, with minutes recorded.
- Reports include complaint volumes, categories, resolution timelines, and root-cause analysis.
- Complaints data is provided to the CBCS upon request, ensuring full regulatory transparency.
- Escalated complaints and recurring issues are reviewed at management level.
- Corrective actions are implemented promptly and tracked for completion.
- Insights from complaints are integrated into risk management processes, staff training programs, and service and product development.
- The proportionality principle is applied, ensuring procedures are effective, efficient, and aligned with the company’s size, complexity, and risk profile, specifically:
- Structure: 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.
- Documentation: Complaints are recorded using a centralized digital register suited to Bitkaya’s current operational scale (e.g., secure Excel-based or cloud database system); automation and reporting capabilities will expand as volumes increase.
- Reporting and Review: Internal reviews occur semi-annually, with additional ad-hoc reviews if trends or high-risk complaints are identified; frequency will scale up as the client base grows.
- Resources: Staff awareness and training on complaint recognition and response are conducted periodically, without imposing excessive administrative burden.
- Scalability: The policy framework, systems, and templates are designed for gradual expansion, allowing seamless adaptation to higher transaction volumes, new jurisdictions, or additional regulatory requirements.
- Bitkaya ensures regulatory compliance, operational efficiency, and continuous improvement while maintaining the flexibility expected of a small but growing VASP.
Evidence
- Expected evidence: Semiannual complaint trend and root-cause report including complaint volumes, categories, resolution timelines, and root-cause analysis
- Expected evidence: Management-review minutes and decisions (at least every 6 months)
- Expected evidence: Corrective-action register and closure evidence (corrective actions implemented promptly and tracked for completion)
- Expected evidence: Training materials, attendance and competence evidence
- Expected evidence: Integration of insights into risk management processes, staff training programs, and service/product development
- Expected evidence: Framework review and approved updates
- Expected evidence: Proportionality and scalability review (structure, documentation, reporting and review, resources, scalability)
- Expected evidence: CBCS data requests and responses
- 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 each semiannual cycle and trace significant trends to decisions, accountable actions and closure; verify integration into risk management, training, and product/service development; confirm proportionality review covers all five aspects
- Testing frequency: semiannual and after material events
Relationships
- Policy: POL-COMP-001 Client Complaints Handling Manual
- Process: PRC-CPO-001 Client Protection and Operations
- Procedure: PROC-COMP-007 Analyze Trends Report Train Review and Improve
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, 13, 14 (root-cause analysis, 6-month review, corrective actions, integration into risk/training/products, proportionality aspects).
- 2026-07-26: Normalized evidence metadata and separated design status from runtime effectiveness.
- 2026-07-26: Created from the approved COMP Manual.