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Platform Operations
Audit, Reporting and Transparency Policy
Requirements for external audit, public reporting, governance-effectiveness metrics and whistleblower protection.
- Version
- v1.0
- Effective
- 2026-07-19
- Last reviewed
- 2026-07-19
- Next review
- 2027-07-19
- Owner
- CFO
- Approver
- Audit and Risk Committee
Applies to
- Financial statements and fee accounting
- IMI methodology and impact reporting
- Governance and compliance operations
Jurisdictions
- Hong Kong (PDPO, IRD s.88)
- United Kingdom (UK GDPR, DPA 2018)
- European Union (GDPR)
- Singapore (PDPA)
- Australia (Privacy Act 1988)
- Japan (APPI)
- Wider APAC per country taxonomy
How this is applied in-product
- Annual external financial audit engagement
- Public Transparency Report at least annually
- Whistleblower channel operated by the Ethics and Compliance Committee
- Audit chain and admin provenance surfaced in /admin/provenance
1. External Audit
- Annual independent audit of financial statements by a qualified Hong Kong firm.
- Independent review of fee accounting and disbursement.
- Periodic (at least biennial) third-party review of IMI methodology and TrustMark issuance controls.
2. Public Reporting
- Annual Transparency Report covering IMI performance, verified action volume, complaints and outcomes, sub-processor changes and material incidents.
- Quarterly headline metrics published on the public site.
- Every material policy change announced with an effective date and rationale.
3. Governance Effectiveness Metrics
- Policy review currency (percentage of policies reviewed within the last 12 months).
- Time-to-resolve for complaints and disputes.
- Verification decision quality (overturned appeals rate).
- Incident MTTA and MTTR.
4. Whistleblower Protection
Confidential intake, protection from retaliation, and independent handling by the Ethics and Compliance Committee, escalating to the Audit and Risk Committee where financial integrity is implicated.
Questions or concerns about this policy? Contact the DPO.