Objective
Ensure ESG objectives, responsibilities, risks and actions receive timely management and Board oversight, with the Board of Directors providing oversight and approving ESG strategies, policies, and key initiatives, and ensuring ESG matters are aligned with the company’s strategic objectives.
Control Activity
Compliance convenes the ESG Committee quarterly — composed of cross-functional leaders from compliance, finance, operations, and HR — records KPI and risk review, tracks actions and escalates material matters. The Board reviews strategy and material performance at least annually. The Compliance & Risk Function ensures ESG principles are embedded into risk management and regulatory compliance processes and monitors adherence to anti-corruption, AML/CFT, and ethical standards.
Verification Requirements
- Verify that the Board has approved ESG strategies, policies, and key initiatives and that ESG matters are aligned with the company’s strategic objectives.
- Verify that the ESG Committee is composed of cross-functional leaders from compliance, finance, operations, and HR.
- Verify that the ESG Committee meets quarterly to review ESG KPIs, risks, and stakeholder concerns.
- Verify that the Compliance & Risk Function monitors adherence to anti-corruption, AML/CFT, and ethical standards.
- Verify proportionality: in Bitkaya’s early stage, ESG responsibilities are combined within existing compliance and operations roles, with plans to formalize a dedicated ESG function as the company expands.
Evidence
- Expected evidence: Approved objectives and responsibility matrix
- Expected evidence: Quarterly meeting papers, minutes and action log
- Expected evidence: KPI, risk and escalation reports
- Expected evidence: Board review and approval evidence
- 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 quarterly meetings and annual Board review for required content, decisions and action closure
- Testing frequency: quarterly
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.