Objective
Ensure complaints are accessible, acknowledged, impartially investigated, timely resolved, escalated, analyzed and retained, consistent with the approved Market Conduct & Trading Compliance Manual v1.1 section 7.
Control Activity
The complaint owner records each complaint, confirms receipt in writing within five business days, provides registration details within two weeks, investigates impartially and resolves it within 30 business days from acknowledgment. Delays require a documented reason and revised timeline. The final response records findings, rationale and corrective action, provides applicable escalation routes and preserves the complete complaint record for at least ten years after resolution. Clients must be informed of clear channels through which they can submit complaints, including email, online portals and dedicated customer service contacts; complaints should be acknowledged promptly (e.g., within two business days) with confirmation of receipt and an outline of the next steps; standard response timelines must be established (e.g., resolution within 30 days, unless extended due to complexity) and clients must be kept updated on progress (MCT 7.1). Each complaint will be handled objectively, without bias toward the company or the client; similar complaints must be treated consistently to ensure fairness across all cases; resolution processes must align with local and international consumer protection laws ensuring that clients receive equitable treatment and outcomes (MCT 7.2). Bitkaya will provide internal escalation procedures allowing unresolved complaints to be reviewed by senior management or the Compliance team; where internal resolution is insufficient, clients will be advised of alternative dispute resolution (ADR) mechanisms, ombudsman services or relevant regulatory complaint platforms; certain complaints may trigger mandatory reporting to regulators particularly if they involve misconduct, systemic issues or breaches of regulatory requirements (MCT 7.3). Each complaint must be recorded with details of the issue, investigation steps, communications and resolution outcome; records must be retained for at least five years, or longer if required by local regulation; complaint data will be regularly reviewed to identify trends, systemic risks and opportunities for process improvements; records must be made available to regulators upon request demonstrating compliance with complaint-handling obligations (MCT 7.4). Where a complaint touches on sanctions, unusual activity review, internal compliance escalation or legal restrictions, the complaint process must remain coordinated with the relevant control function; complaint handling must not override legal, compliance or confidentiality obligations; responses must be accurate and clear but must not disclose information in a manner that breaches anti-tipping-off or other legal restrictions (MCT 7 intro).
Evidence
- Expected evidence: Complaint intake and acknowledgement (clear channels: email, online portals, dedicated customer service; prompt acknowledgment with receipt confirmation and next steps)
- Expected evidence: Investigation and client updates (impartial review without bias; consistent treatment; consumer protection standards alignment)
- Expected evidence: Resolution, redress and escalation (internal escalation to senior management or Compliance; external ADR, ombudsman, regulatory complaint platforms)
- Expected evidence: Regulatory-reporting assessment (mandatory reporting where misconduct, systemic issues or regulatory breaches are involved)
- Expected evidence: Ten-year retention evidence (records retained at least five years or longer if required by local regulation; available to regulators upon request)
- Expected evidence: Complaint trend analysis (regular review to identify trends, systemic risks and process-improvement opportunities)
- Expected evidence: Anti-tipping-off compliance (responses accurate and clear but not disclosing information in breach of anti-tipping-off or other legal restrictions)
- Expected evidence: Coordination with control functions where complaints touch on sanctions, unusual activity review, internal compliance escalation or legal restrictions
- 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 complaints for acknowledgement, ownership, investigation, timeline, escalation, confidentiality, closure and retention; verify impartial and consistent treatment; confirm regulatory reporting assessment for misconduct, systemic issues or breaches; confirm anti-tipping-off compliance and coordination with control functions for sanctions or compliance-related complaints.
- Testing frequency: per complaint with periodic trend and overdue-case review
Relationships
- Requirement: REQ-VASP-010 Maintain Client Complaint Handling
- Policy: POL-MCT-001 Market Conduct and Trading Compliance Manual
- Process: PRC-CPO-001 Client Protection and Operations
- Procedure: PROC-MCT-006 Handle Market Conduct and Trading Complaints
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 MCT Manual version 1.1.
- 2026-07-26: Aligned service levels, final-response requirements and retention with the Board-approved COMP Manual.