Objective
Ensure ESG reporting is accurate and approved and the ESG framework remains proportionate and improves over time, disclosing ESG performance through an annual sustainability statement aligned with recognized frameworks (e.g., GRI, SASB), and ensuring all proportionality measures are documented, reviewed, and updated for transparency and traceability.
Control Activity
Compliance reconciles annual ESG reporting to source evidence, obtains management and Board approval, completes an annual proportionality assessment and tracks approved improvements. This includes verifying that ESG performance is disclosed through an annual sustainability statement aligned with recognized frameworks (e.g., GRI, SASB), all proportionality measures are documented (including ESG meeting notes, policy updates, training logs, and compliance reviews), an annual proportionality assessment is led by the Compliance Officer evaluating whether governance, ethics, and ESG measures remain appropriate to Bitkaya’s operational profile, findings are reported to the Management Board for approval, and improvements are tracked including gradual enhancement of systems and reporting frameworks, integration of ESG data tools and automation, benchmarking against international ESG standards and peer practices, and periodic independent assessments of ESG maturity and proportionality adequacy.
Verification Requirements
- Verify that ESG performance is disclosed through an annual sustainability statement aligned with recognized frameworks (e.g., GRI, SASB).
- Verify that all proportionality measures are documented, reviewed, and updated for transparency and traceability.
- Verify that records include ESG meeting notes, policy updates, training logs, and compliance reviews.
- Verify that an annual proportionality assessment is led by the Compliance Officer.
- Verify that proportionality assessment findings are reported to the Management Board for approval and implementation of required enhancements.
- Verify that improvements include gradual enhancement of systems and reporting frameworks as complexity increases.
- Verify integration of ESG data tools and automation for monitoring and reporting.
- Verify benchmarking against international ESG standards and peer practices.
- Verify periodic independent assessments of ESG maturity and proportionality adequacy.
- Verify proportionality: include ESG summaries in annual governance statements; transition to full sustainability reporting (aligned with GRI/SASB frameworks) as regulatory scope and operations expand.
- Verify alignment with supervisory expectations under the Central Bank of Curaçao and Sint Maarten (CBCS), the National Ordinance on the Supervision of Virtual Asset Service Providers (NOSVASP), and international ESG best practices.
Evidence
- Expected evidence: Metric definitions, source data and reconciliations
- Expected evidence: Draft, review, approval and final reporting
- Expected evidence: Annual proportionality assessment
- Expected evidence: Improvement plan and closure evidence
- 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: trace a sample of claims and metrics to evidence and inspect review, approval and improvement follow-up
- Testing frequency: annual
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.