How to Undertake an Investigation in Your Organization

Have you ever thought about what your business should or would do if a report that something unethical was happening? Would you run an investigation internally or outsource to a professional? While there are advantages to considering either model, if you choose to run an investigation internally, you’ll need to define a process and decide what you’ll do with the results that are uncovered. Consider X tips on undertaking an internal investigation with confidence.

The Importance of Planning

Before you do an investigation, you should make sure you have everything you need.   Have you assessed your organization?  Who are your first responders, what resources (financial and personnel) do you have available?  Do you have a procedure?  Consider the following procedure!

  1. Create a plan for triaging reports
  • Determination whether the tip or complaint justifies an investigation.
  • Does it potentially require legal counsel? Law enforcement?
  • Who is the investigator?
  • What are the objectives?  This may include restitution if the wrongdoing is financial.
  • This aspect should solidify all the details
  1. Handle the report
  • Maintain confidentiality
  • Good communication skills are crucial
  • Let concerned party know you take the report seriously – and make sure you do actually take it seriously
  • Get as much information from complainant during the initial communication as in the case of a whistleblower or anonymous information, follow up may be difficult or impossible
  1. Determine who should conduct the investigation
  • Do-it-yourself
    1. Appropriate as long as it’s well-defined in organizational policy
    2. Objectivity in the matter is crucial
    3. Perception of objectivity is also highly important
    4. Determine what’s in the best interest of the organization
  • Internal specialist
  • . This should be someone who is specially designated for this task
  1. Needs to have sufficient knowledge or experience in the investigation topic including understanding their own legal limits
  2. Crucial for the person to be impartial and fair including not having the appearance of bias or conflict
  3. There should not be a conflict of interest or investment in the outcome of the investigation
  4. Individual must be discreet and maintain confidentiality
  5. So you’ve decided to handle the investigation in-house whether by managing it yourself or through an internal specialist.  Here are the steps you need to take to ensure a strong and ethical investigation.
  1. Gather evidence

According to an article on investigating tips, “Evidence is defined as anything used to determine or demonstrate the truth of an assertion.” You want to get the whole picture from all sides so evidence is crucial.   The aforementioned article lists the following as possible sources of physical evidence (p. 9):

“Documents, including schedules, PowerPoint presentations, PDFs, checks, bank statements, invoices, contracts, procedures, policies, financial statements, handwritten notes, books and records – note that these may be paper or electronic documents Computer records, such as e-mails or files. The field of computer forensics has produced some powerful investigative evidence in recent years.  Other types of physical evidence, such as cash, fingerprints and writing samples.  In corporate settings, this type of evidence is less prevalent than documents and computer records.

  1. Conduct interviews
  • Interview the witnesses first
  • Secondly, interview the complainant
  • Interview the accused last, after you have gathered all of the other information.
  • Ask open-ended questions (avoid yes/no questions)
  • Frame it as a discussion.
  • Allow interviewee to speak without interruption, judgment, or time limits
  • What tone do you want the interview to have?  Causal? Direct?  Where you schedule the interview also sets the dynamic – your office, conference room, interviewee’s office – all have different advantages and challenges.
  1. Document the interviews

Taking notes can be helpful, but it can also distract you from the interviewee. Consider recording the interview as that documents all that is said without room for note taker error and also protects you from accusations of wrongdoing.  iRecord offers a turnkey solution to recording investigative interviews.

  1. Repeat these steps through every interview to ensure consistency, fairness, and equity.

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