As an employer, manager or investigator, you are always looking for ways to improve internal investigations. A Deloitte report titled “Ten Things to Improve Your Next Internal Investigation” provides some solid advice. When putting the report together, a team from Deloitte met with investigators from different companies and collected their best advice to pass on to other investigators.
Here are the top 10 tips as presented in the report:
1. A Little Preparation
Everyone needs to understand their role in the investigation and what responsibilities they are in charge of carrying out. In the report, there was a quote from Juniper Network’s GC Mitchell Gaynor, which I think is one of the best explanations as to why investigation planning is so important:
“It’s important for whoever is chosen to lead the investigation to have a process to be able to explain the process, know the next steps, and provide management with a strong sense of confidence. Otherwise, executives may feel the need to take actions on their own that ultimately can be counterproductive and unintentionally undermine the investigation.”
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2. Know your Team
The number of people involved in an investigation will vary on a case-by-case basis – and so will the required skill sets. Make sure you have the right people on board. Carefully select investigators and other professionals based on their experience and skill in order to avoid compromising the investigation.
3. A Prompt and Prudent Response
Consistency is important. Management can’t pick and choose which tips to investigate. The same rules apply to anonymous whistleblower tips. Give each incoming complaint/tip the same amount of attention and determine whether or not a full investigation will be required.
4. Investigations are Different from Internal Audits
Internal audits and investigations have two very different purposes. An internal audit isn’t the answer to getting to the root of a complaint – an investigation is.
5. Diligent but Efficient
It can be hard for investigators to balance acting quickly and maintaining investigation quality. The report enforces the importance of staying focused on the allegation, locking down documents and other evidence immediately and don’t jump to conclusions.
6. Loose Lips…
Uphold confidentiality. Don’t talk about the investigation in public or in any place where other employees could hear. During the investigation interviews, remind each person to do the same and refrain from discussing any investigation information with fellow employees. If the details of the investigation go public, the entire investigation could be compromised and employees will be reluctant to report future incidents.
7. Navigating Global Differences
In yesterday’s post we discussed some of the challenges brought on by cross-border investigations. One of the main concerns during cross-border investigations is access and transfer of information. Data privacy laws differ between countries and can act as barriers to accessing evidence and completing an investigation in a timely fashion. Culture, language and business laws also influence cross-border investigations.
8. Anticipating the Unexpected
Don’t let an unexpected event throw you off during an investigation. Some of the unexpected events listed in the report include: witnesses requesting legal representation during interviews, evidence of other misconduct may surface, employees involved in the investigation may resign and so on. You can’t predict these events, you simply have to work with them.
9. It’s Not Only What They Say but Also How They Say It
Pay attention to nonverbal queues during investigation interviews. However, remember to be careful. Don’t jump to conclusions and assume someone is guilty just because they demonstrate one of the nonverbal queues – some of the same signs also signal nervousness. Also, just because someone doesn’t seem like they’re lying doesn’t mean they are telling the truth. The more time someone has to orchestrate a story, the more time they have to review it and become comfortable telling it.
10. Creating More Value
What do you do with investigation information once the investigation is over? Use this opportunity to improve employee training programs and revamp company policies. In some cases, the investigation could show that there’s a flaw in your business processes, making it easier for employees to get away with theft, fraud or some other type of misconduct. Take this information to make improvements and prevent similar incidents from occurring in the future.