An investigation is a legitimate and formal review designed at establishing and documenting facts, following the allegation or suspicion of misconduct.
Improvised investigations expose organizations to further risks of non-compliance and reputation damage.
Hence, internal investigations policies, processes and approaches need to be defined before allegations or suspicions are raised. The investigation process needs to be seemingly integrated with the whistleblowing process.
We build our client’s capacity to appropriately handle allegations or suspicions of misconducts.
what we do
We conduct internal investigations of suspected or alleged misconduct, including fraud, corruption, insider trading, discrimination and harassment.
what we do
A large multinational company (USD 10bn+ in revenue, 45,000+ employees across 30+ countries) lacked a unified internal investigation process. Decisions on Internal Investigations were taken on a case by case basis and conducted in silos by different functions (HR, Security, Internal Audit, Compliance, etc.)
The Chief Audit Executive (the Client) asked us to draft a new Internal Investigation Policy, applicable across all entities and departments globally, aligned with the Company’s Code of Conduct and hotline policy.
Based on information collected through document review and interview of key stakeholders, we build a new, principle based, internal investigation process, clarifying the approach to be followed and allocating investigation accountability based on independence and subject matter expertise. The policy covered the entire process, from the assessment of concerns to the reporting to the Board.
The new investigation policy was approved by the company’s Executive Committee and Board. It gave a clear mandate to the Internal Audit department and provided visibility on investigations management to the Board.
An international NGO uncovered an undisclosed conflict of interest scheme involving one of its top executives. They needed to make a preliminary assessment to understand if this conflict was an isolated incident or a pattern of misconducts.
The Head of Legal asked us to help them properly document the policy violation and uncover other potential integrity lapses.
We designed and rolled out an investigation work program including review of expense reports, purchasing approvals, signed contracts as well as email communications, based on key word searches and cross referencing. All the data and documents reviewed were kept on the organization’s network.
We released an investigation report, clearly establishing that internal policies on conflicts of interests and gifts had been violated by the executive. The NGO was able to use this report to justify disciplinary measures taken against the executive. We made recommendations to the NGO on the improvement of its conflicts of interest and gift policy framework.