Objective
Ensure all in-scope personnel receive and acknowledge the current Employee Handbook.
Control Activity
Compliance and Human Resources maintain the in-scope population (all employees, officers, directors, contractors, consultants, agents, joint ventures, and any third parties acting on behalf of Bitkaya, regardless of location), issue the current handbook, obtain employee and manager signatures on the Employee Handbook Acknowledgment Form, retain evidence and escalate missing or overdue records.
The acknowledgment must confirm: (1) the employee has read and understood the handbook contents, (2) agreement to follow the rules, standards, and principles, (3) understanding that failure to follow policies may result in disciplinary action up to and including termination and may be reportable to regulators or law enforcement, and (4) understanding that the handbook does not create an employment contract.
Evidence
- Expected evidence: In-scope personnel list
- Expected evidence: Current handbook distribution record
- Expected evidence: Signed or electronically authenticated acknowledgments
- Expected evidence: Overdue reminders and escalations
- Evidence location: source evidence in SYS-ECM-001 Compliance Framework Library, 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: reconcile a sample of current and newly engaged personnel to a complete acknowledgment for the applicable handbook version
- Testing frequency: quarterly and after material handbook change
Relationships
- Requirements: REQ-VASP-003 Maintain Governance and Fit and Proper Oversight, REQ-VASP-005 Maintain Integrity Based Business Operations
- Policy: POL-EMP-001 Employee Handbook
- Process: PRC-RSA-001 Resilience Systems and Assurance
- Procedure: PROC-EMP-001 Onboard Employees and Maintain Handbook Acknowledgments
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
- 2026-07-26: Normalized evidence metadata and separated design status from runtime effectiveness.
- 2026-07-26: Created from the approved Employee Handbook version 1.0.