This week, HP agreed to a $55 million settlement with the US Department of Justice, ending the month of August in the news- the same place the company found itself in at the start of the month. Some of our other posts this week focused on information to include in investigation reports and how your company’s CIO and CSO can be used as key players in ethics and compliance. Here’s a review of our posts from this week:

Monday:

• Blog Post- Top 10 Investigation Report Must Haves

“Is this what you look like when it comes to preparing investigation reports? Writing investigation reports doesn’t have to be daunting. A standardized reporting structure improves the consistency of reports amongst investigators. Standardized reporting provides investigators with a reporting format to follow and reduces the time spent preparing investigation reports. This information is all fine and dandy, however, a question we frequently receive is, what information do I actually need to put in an investigation report?”

Tuesday:

• Blog Post- 3 Ways Your Chief Information and Chief Security Officers Can Be Ethics Heroes

“A company’s ability to effectively use technology to monitor, share and manage information contributes to the success of its ethics and compliance program. Some laws and corporate policies contain compliance requirements that can only be executed by a company’s IT department. In my opinion, a company’s Chief Information Officer (CIO) and/or Chief Security Officer (CSO) is equally as important as the Chief Ethics and Compliance Officer (CECO) when it comes to maintaining workplace ethics and compliance. Since CIOs are responsible for implementing IT systems and controlling the flow of information into and out of a company, CIOs help protect their company from data breaches and other technical risks. As ethics and compliance grows as an IT concern, an increasing number of companies have reported looking for CIOs, CSOs and other IT staff that not only possess the required technical skills, but also have personal values and morals that are similar to those of the company.”

Wednesday:

• Blog Post- 3 Things HP Should Add to Their Ethics “To Do” List

“So long sweet summer. However, for the folks at HP, the past month has been anything but sweet. In early August, HP announced the resignation of Mark Hurd following an internal investigation into sexual harassment allegations made against the now former CEO. As August ends, HP is making headlines again- this time following an investigation into alleged kickbacks paid by the company. HP agreed to a $55 million settlement, as the company was accused of paying kickbacks to the US government in exchange for business contracts. Here’s a look at the past month at HP, as well as some lessons the company should consider applying when rebuilding its corporate ethics.”

Thursday:

• Blog Post- i-Sight Ethics and Compliance Software on Display at the ECOA Business Ethics and Compliance Conference

“September is shaping up to be a busy month for us at Customer Expressions, as we announce today that we will be exhibiting the i-Sight Compliance and Ethics Investigation Software at the 18th annual Business Ethics and Compliance Conference. The conference is hosted by the Ethics & Compliance Officer Association and this year it’s being held in Anaheim, California from September 21-24th. We attended this conference last year when it was held in Chicago and are glad to be returning again this year.”

Is this what you look like when it comes to preparing investigation reports? Writing investigation reports doesn’t have to be daunting. A standardized reporting structure improves the consistency of reports amongst investigators. Standardized reporting provides investigators with a reporting format to follow and reduces the time spent preparing investigation reports. This information is all fine and dandy, however, a question we frequently receive is, what information do I actually need to put in an investigation report?

 Here is our answer to that question:

1. Information to Identify the Case:

Begin the report with case specific information that identifies the case the report is related to. Include information such as the investigator’s name, case number, the date the case was entered and the date it was assigned to the investigator.

2. Referral Source:

The next section should include the complainant’s information. The complainant’s work phone number, e-mail, employee number, office location, department and job title help identify the person lodging the complaint.

3. Allegation Details:

Harassment, discrimination, retaliation — what type of allegation is under investigation? In this section, be sure to include as much detail as possible about the initial complaint.

• Identify the type of case.
• Who the alleged victim is- may or may not be the same person as the complainant.
• How the complaint was received- hotline, face-to-face, web form, etc.
• Allegation details- what happened, where, when and any other information provided in the initial complaint.

4. Information About the Subject:

The information required for this section of the report is similar to that of the “Referral Source” section. However, it’s the subject’s (the accused person’s) information being documented this time. Include their name, e-mail, work phone number, office location, department and job title.

5. Investigation Scope/ Purpose:

Include a statement that describes the mission and objectives of the investigation. Answer the question “what is the investigation trying to prove?”.

6. Case Notes:

The case notes section should include an overview of the tasks assigned and action taken throughout the investigation. Be sure to include a brief description of the task, steps taken to complete it, who completed the task and when.

7. Interview Summaries:

List the investigation interviews that took place throughout the investigation. Make sure the list is in chronological order, beginning with the first interview, ending with the last. Summary details are short and sweet, outlining:

• Name of the interviewer- also include the names of any other people who sat in on the interview.
• Name of the person interviewed and their role in the investigation- complainant, subject, witness.
• Interview location.
• Date of interview.

In this section of the report, there’s no need to go into detail about the events of the investigation- that’s what the next section is for!

8. Interview Reports:

Interview reports are brief summaries of each of the investigation interviews. In addition to the information in the above section, this part elaborates on the investigation interview to include:

• Credibility Assessment- Certain factors will determine the credibility of an interviewee’s statements. We cover the topic of determining credibility in our post “Investigation Interview Questions to Determine Credibility“. This section of the report should list any indicators that contribute to the belief that the interviewee is or isn’t a credible source.
• Investigator Notes- Summarize the introduction, incident overview and conclusion of each interview. In the introduction, outline the explanation of the interviewer’s role in the investigation, the purpose for the interview, efforts to maintain confidentiality and retaliation protections. The incident overview section should include the interviewee’s description of events related to the incident, whether or not they are aware of any witnesses, where/when the incident occurred and any background information linking the involved parties. Notes to be made about the interview conclusion should include thanking the interviewee, reiteration of confidentiality concepts, review of statements made and interviewee singing of investigator notes.

9. List of Evidence:

As simple as it sounds- list the evidence collected during the investigation. For the sake of the investigation report, include information such as:

•  Type of evidence collected- interview, video, photo, audio tape, e-mail, etc.
• Name of person who presented the evidence, as well as their role in the investigation.
• Date the evidence was collected.
• Location of the evidence.

10. Recommendations:

Conclude the report with recommendations. After reviewing all of the investigation materials, what type of action should be taken? Does evidence support the violation of workplace policies? Make sure recommendations are backed up by the consequences outlined in the company code of conduct or other policies governing employee behaviour in the workplace. Include a plan of action, identifying next steps in taking corrective action.

Reporting With a Case Management System

Case management solutions simplify the investigation reporting process, creating reports with the click of a button. Initially, a report template needs to be developed, outlining the sections of the report. Information from the investigation is pulled from the case file, automatically filling in each of the sections in the report. The report is then ready for export, with the investigator choosing the desired format for the report (PDF, MS Word document, etc.).

This week we focused on the tactics Xerox used to rebuild its corporate impage after the 2002 accounting scandal charges. Other topics discussed this week include investigating sexual harassment allegations in the workplace and measures companies can use to protect the personal information of employees and clients. Here’s a review of our posts from this week:

Monday:

• Blog Post- Xerox’s Accounting Scandal Recovery Tactics

“The turn of the century was marked with a number of accounting and ethics scandals that would significantly alter the importance of corporate ethics and compliance. The Securities and Exchange Commission (SEC) began investigating the accounting practices at Xerox in 2000, which eventually led to Xerox agreeing to pay a $10 million settlement. During Xerox’s post-scandal transformation, Sarbanes-Oxley came into effect to improve financial and accounting compliance. Today, Xerox has turned their practices around and secured a spot on numerous ethical company lists. This post discusses the tactics deployed at Xerox to regain consumer confidence and instill ethics and compliance back into the company.”

Tuesday:

• Blog Post- The SCCE’s Annual Compliance & Ethics Institute in Chicago

“We, Customer Expressions, will be sending a team down to Chicago to attend the  Annual Compliance & Ethics Institute, hosted by the Society of Corporate Compliance and Ethics. The conference runs from September 12-15 and features presentations from chief compliance and ethics officers, CEOs, certified compliance and ethics professionals, lawyers, compliance analysts and many other professionals in the field of ethics, compliance and risk management. While we are away, we will be blogging from the event and interviewing industry professionals.”

Wednesday:

• Blog Post- Investigating Workplace Sexual Harassment Allegations

“Sexual harassment occurs all too frequently in the workplace. Many recent sexual harassment allegations that have been made have been directed at top level executives. As investigators, you understand the value of maintaining compliance, confidentiality and promptness when investigating incidents of sexual harassment. Regardless of the employee’s level in the organization, each investigation must be handled with objectivity, follow company policies and reprimand those found guilty of policy violations. Previously, we blogged about a number of sexual harassment related topics, including developing anti-sexual harassment policies, tips for preventing and detecting sexual harassment, as well as the different forms of sexual harassment against males and females in the workplace. This post will focus on addressing sexual harassment complaints and investigations into sexual harassment allegations, to ensure company policies are enforced and violators face appropriate consequences.”

Thursday:

• Blog Post- Gaining Control Over Personal Information Privacy

“The issue of personal information protection is a hot topic. Companies such as Google and Facebook have been questioned in regards to their privacy policies, as the personal information gathered from users has been leaked to the public on multiple occasions. Most recently, the University Health Network made headlines when patient information was leaked due to the theft of an unprotected USB key- we discussed the topic in the post “Maintaining Information Security and Privacy.” Sharing information has been made easier due to the Internet and electronic files, which raise concerns when it comes to regaining control over personal information protection. As technology advances, the risks surrounding information privacy continue to increase. Will your organization be ready to respond to tighter information controls?”

This week we continued to look at the lessons learned from the HP CEO ousting, as well as the dramatic exit of JetBlue employee Steven Slater. Focusing on key topics such as tips for detecting harassment and discrimination in the workplace and employee theft investigations, here’s a review of our posts from this week:

Monday:

• Blog Post- Civacon Reduces Complaints and Reporting Time With i-Sight Quality and Correction Action Software

“Many of us rarely think about where products come from or how they arrived at their destination safely. Much of what we use and consume on a daily basis goes through many steps and precautions along the way through a company’s supply chain.  Civacon is the world’s leading provider of cargo tank components and systems designed for safe, profitable handling and transportation of hazardous bulk products. Civacon’s vents, valves and other equipment help safeguard against petroleum, liquid and chemical spills and get dry bulk commodities to their destinations. In order to effectively manage complaints and quality issues, Civacon implemented the i-Sight Quality and Correction Action Software.”

Tuesday:

• Blog Post- The Warning Signs of Workplace Harassment and Discrimination

“For some, the work environment can be an unwelcome place. Employees who fall victim to workplace discrimination or harassment react differently- some confront the issue by discussing it with their manager, while others, in the case of last weeks feed up JetBlue employee, grab a beer, release the emergency exit and slide on out in a dramatic exit. Employees don’t always feel comfortable bringing harassment and discrimination incidents forward, as fear of retaliation and being singled out by fellow employees adds additional stress to the employee. In some workplaces, the culture and tone from management may also hinder an employee’s willingness to come forward. In many jurisdictions, employers are legally responsible for providing employees with a safe, harassment and discrimination free workplace. Employers need to know how to monitor and recognize signs of harassment and discrimination in the workplace. Recognizing the signs and symptoms of distressed employees helps to identify workplace issues and draws attention back to sections of the company code of conduct that may need to be reinforced or require additional training.”

Wednesday:

• Blog Post- Conducting Effective Employee Theft Investigations

“According to a report from the Association of Certified Fraud Examiners, occupational fraud and abuse costs businesses in the United States upwards of $400 billion a year. Today’s business leaders must focus on protecting their brands through prevention and proactive measures to rid their workplace of fraud, theft, violence and other unethical acts. However, managers still need to be prepared to react to these types of events and conduct investigations into reported allegations, as accidents do happen. One of the main concerns facing businesses during times of economic recession is employee theft. As businesses do their best to cut unnecessary costs, they must also monitor for theft, as the costs associated with theft place significant burdens on the organization. We have covered tips for preventing and detecting employee theft in our posts “Workplace Theft & Fraud Prevention Tips Part 1,” and “Workplace Theft & Fraud Prevention Tips Part 2,” therefore, this post will focus on the proper handling of workplace theft allegations and conducting employee theft investigations.”

Thursday:

• Blog Post- Learning From Ethical Lapses

“There have been countless articles written since August 6^th, when HP ousted their now former CEO, Mark Hurd. In particular, this article from the Wall Street Journal focuses on the importance of proper expense reporting and how the HP example has already served as a lesson in numerous workplaces. The article features comments from ERC President, Patricia Harned, in which she states:

“Companies will often use very public cases as a teachable moment to remind employees why certain policies are so important.”

The article discusses the increased harshness faced by executives who make poor, unethical decisions, as they are supposed to be leaders and set an example for their employees. The article also features a great discussion about the importance of administrative staff in detecting inaccurate or unjust expenses.

It seems to be that each week is busier than the last. Here are some of the things we blogged about this week- as well as some other pieces that caught our attention regarding internal investigation, human resources and ethics:

Monday:

• Blog Post- Maintaining Information Security and Privacy

“Early last week, a USB key containing hundreds of Ontario patient health information files was stolen. According to the CBC, the USB wasn’t encrypted and was stolen from the purse of a University Hospital Network (UHN) employee. The theft of these files has resulted in a call for efforts to increase the security of sensitive information. This is the second instance in under a year where private patient information was compromised in Ontario due to theft. The lesson learned from this story can be applied to any business that maintains client or customer personal information records: make sure sensitive information is encrypted. Controlling access to information can further prevent information security breaches, as the number of people viewing sensitive information is decreased. Regular evaluation of training programs and internal procedures related to information security must be undertaken to ensure each employee is completing the necessary steps to safeguard information. ”

Tuesday:

• Blog Post- HP CEO Violates Company Code of Conduct

“On Friday, HP CEO Mark Hurd was asked by the company’s board of directors to submit his resignation. As reported in the TechCrunch Article “HP CEO Mark Hurd Resigns, This Looks Messy,” the outcome of an investigation into sexual harassment allegations against Hurd “concluded that there was no sexual harassment violation, however it did find that Hurd violated HP’s ‘Standards of Business Conduct.‘” When news broke about his departure, Hurd claimed he himself hadn’t lived up to his own standards regarding integrity and respect. Therefore, if he wasn’t able to live up to these standards himself, what message does that send to the rest of the employees at HP?”

Wednesday:

• Blog Post- Whistleblowers Granted Additional Protections Under Dodd-Frank Act

“Employers must be prepared to follow new legislation that has been enacted to increase protections for whistleblowers. The recent passing of the Dodd-Frank Act continues to follow the trend towards putting an end to whistleblower retaliation- as well as rewarding whistleblowers for bringing forward evidence of unethical or criminal acts taking place within an organization. Whistleblowers can become victims of retaliation whether it comes from managers or fellow employees.”

Thursday:

• Blog Post- Ethics Resource Centre Releases Information on the Cost of Workplace Retaliation

“As part of the National Business Ethics Survey conducted by the Ethics Resource Centre (ERC), the ERC releases supplemental research briefs that focus on a number of topics from the survey in a more detailed manner. The most recent release featured information pertaining to the cost of retaliation on both the company and its employees. As mentioned in yesterday’s post about the Dodd-Frank Act and its whistleblower protections, retaliation is a growing concern in the workplace. In many organizations, employees are an employer’s eyes and ears when it comes to catching workplace misconduct. To establish a workplace that is safe and enjoyable for all, employers must work to create an environment that encourages the reporting of misconduct. The ERC survey concluded that companies with a zero tolerance policy for retaliation experienced very few instances of retaliation, which demonstrates that efforts to prevent retaliation do have an impact.”

It seems to be that each week is busier than the last. Here are some of the things we blogged about this week- as well as some other pieces that caught our attention regarding internal investigation, human resources and ethics:

Tuesday:

• Blog Post- Deloitte’s 2010 Ethics & Workplace Survey

“As with any human relationship, once the trust is gone, the relationship usually goes with it. Last week, Deloitte released the findings of their annual Ethics & Workplace Survey. The focus of the survey this year was on trust in the workplace. Deloitte began publishing their annual Ethics & Workplace Survey back in 2007.  The points of concern identified in the survey provide business leaders with insight into growing issues that must be addressed in order to retain valuable employees. The ethics and trust gaps identified in the survey bring to light the different views employees and employers have in regards to these two areas. After reviewing the results and methodology of the 2010 Ethics & Workplace Survey, I have put together some advice for rebuilding ethics and trust within the workplace.”

Wednesday:

• Blog Post- Ethics Resource Centre

“For the past 88 years, the Ethics Resource Centre (ERC) has been a source of information and guidance for ethics and compliance professionals everywhere. The information provided by the ERC serves as a benchmark for companies when gauging the success of their own ethics and compliance programs. The ERC conducts both national and private, single organization surveys, and publishes the results to help businesses and government agencies understand trends, gaps and best practices in ethics and compliance.”

Thursday:

• Blog Post- Investigations in the Financial Services Industry

“Workplace investigations vary between industry sector and must be tailored to the incident under investigation. In the financial services industry, there is an increased number of risks companies face, especially during tough economic times. Fraud, money laundering and compliance issues are only a few basic examples of financial crimes that require timely, thorough investigations. Financial crimes not only impact the reputation and sustainability of companies, but these crimes also have severe social impacts that change the lives of investors and the public at large. For example, the Madoff ponzi scheme left hundreds of thousands of people without their entire life savings, and for some, bankruptcy.”

Workplace investigations vary between industry sector and must be tailored to the incident under investigation. In the financial services industry, there is an increased number of risks companies face, especially during tough economic times. Fraud, money laundering and compliance issues are only a few basic examples of financial crimes that require timely, thorough investigations. Financial crimes not only impact the reputation and sustainability of companies, but these crimes also have severe social impacts that change the lives of investors and the public at large. For example, the Madoff ponzi scheme left hundreds of thousands of people without their entire life savings, and for some, bankruptcy.

Today, investigations in the financial services industry are incredibly complex, as schemes cross multiple borders and are global in scope. This post covers some of the challenges investigators encounter during financial investigations, as well as some solutions for implementing flexible reporting systems that make it easier to conduct investigations on a global scale.

Financial Services Investigations

As with any type of investigation, once a tip or information pertaining to the presence of a financial crime has been received, a preliminary investigation must be conducted immediately to determine if the information warrants a full-fledged investigation. If the allegations lead to suspicious activity, the case must be assigned to the appropriate investigator in order to conduct the investigation in a timely manner. Gathering evidence and conducting interviews are challenging in a financial crime investigation. According to the IRS:

“Financial investigations are usually very document-intensive. Specifically, they involve records, such as bank account information, real estate files, motor vehicle records, etc., which point to the movement of money. Any record that pertains to or shows the paper trail of events involving money is important. The major goal in a financial investigation is to identify and document the movement of money. The link between where the money comes from, who gets it, when it is received and where it is stored or deposited, can provide proof of criminal activity.”

Managing the large volumes of evidence associated with financial crimes investigations can be overwhelming and difficult to track. i-Sight simplifies evidence management by allowing evidence to be attached directly to the case file. Electronic evidence- e-mails, documents, images, video and audio clips; can be attached directly to the case file. To manage physical evidence, i-Sight generates printable barcodes that can be attached to the exhibit and records information in the case file.  Exhibits are automatically numbered and categorized (witness statement, interview video, etc.). Investigators can also describe the contents of the exhibit for easy reference within the case file.

Compliance with state and federal laws are mandatory requirements for all financial crime investigations. Compliance standards are built into the workflow rules in i-Sight to ensure compliance with laws such as the Bank Secrecy Act, Sarbanes-Oxley, Basel II and the Patriot Act. As laws and regulations are amended, changes can be easily made to the i-Sight system to reflect the updated laws. 

Manually reporting on financial crime investigations is incredibly time consuming, as there’s a lot of information to sort through. Investigation software drastically reduces reporting time by extracting information and evidence from within the case file and placing in a customized investigation report template at the click of a button. Information gathered during a financial crime investigation usually needs to be shared with members from other agencies and regulatory bodies. State agencies and other regulators can be granted access to specific cases in i-Sight as needed, allowing them to view and print the data required to support criminal proceedings. This feature makes it easier to share information. Privacy is maintained as case access can be granted and restricted as needed.

Lastly, implementing a web-based investigation software system helps investigators overcome geographic barriers during investigations. i-Sight stores cases in a centralized location, making them accessible from any location. Since many financial crimes involve cross border transfers of money, investigative teams overseas can collaborate on investigations with investigators in North America- all that’s required is an Internet connection. Web-based solutions reduce the amount of time spent on investigations, while also reducing investigative costs, as the amount of travel requested of investigators is greatly reduced.

i-Sight Investigation Software for Financial Services

Regulatory drivers including the BSA, Patriot Act, Basel II and Sarbanes-Oxley have created a demanding mandate for financial institutions. i-Sight Compliance Investigation Software provides financial institutions with a workflow driven solution for managing compliance investigations. i-Sight is fully customizable, designed to ensure compliance with the above mentioned regulations and legislation. i-Sight provides investigative units with a system to quickly respond to suspicious claims and other fraud alerts. i-Sight uses a workflow engine to ensure proper assignment of cases and escalation of cases or tasks that are overdue. Investigators are able to record contacts, notes, activities, evidence, and generate emails, template letters and to-do’s.

It seems to be that each week is busier than the last. Here are some of the things we blogged about this week- as well as some other pieces that caught our attention regarding internal investigation, human resources and ethics:

Monday:

• Blog Post- Integrating Ethics and Compliance Into the Entire Organization

“There’s no point investing in and implementing an ethics and compliance program unless the time is spent integrating the program into every aspect of an organization. The need for companies to develop effective ethics and compliance programs has been acknowledged by several government agencies- examples are the SEC in the US and the government in the United Kingdom. Both groups have recently passed legislation or made amendments to existing guidelines, focusing heavily on the importance of ethics and compliance at all levels of an organization- especially at the top. Employees at each level contribute to the success of a company’s ethics and compliance program. Integrating ethics and compliance at each level helps ensure the message from the top makes it all the way down to the lower levels of the organization. Training, messages and other ethics and compliance initiatives must be developed to evolve with employees as they move through the company. That being said, employees at various levels need to be prepared to address different ethical issues they may encounter based on the role they play in the organization.”

Tuesday:

• Blog Post- Reducing the Opportunity for Workplace Fraud

“The values associated with workplace fraud continue to rise- especially during economic downturns. Preventing workplace fraud begins on the inside of an organization. One of the largest fraud risks companies must address is the opportunity for fraud to occur. There are a number of anti-fraud techniques and systems that are easy to implement within any organization. When fraud grows out of control within an organization, reputations and public trust are destroyed. To reduce the opportunity for fraud to occur, accounting and money handling responsibilities must be divided. Monitoring and enforcement of anti-fraud programs is necessary in order for the program to be effective and for employees to take it seriously. When employees know they are being watched, their work is being reviewed on a consistent basis and punishments are administered to those who violate anti-fraud policies, there’s less room for fraud to go undetected.”

Wednesday:

• Blog Post- Recovering From Ethical Lapses and Investigations: Siemens

“The $1.6 billion fine handed down to Siemens in 2008 was much more than a record breaking fine, it was a lesson for other companies to learn from. Prior to the bribery scandal, Siemens had an ethics and compliance program in place, however, there was a missing link between leadership and the enforcement of the program. The company’s cooperation during the SEC investigation lead to a reduced penalty, but also gave way to a complete re-design of the company’s internal ethics and compliance controls. There are many lessons learned from the Siemens charges, the reaction to the investigation and the actions taken by Siemens to position the company as an ethics and compliance leader in the post-scandal era.”

Thursday:

• Blog Post- The Importance of Investigation Interview Credibility

“In order for a workplace investigation to be credible, investigators must deploy certain tactics to verify the accuracy of interview responses. In a previous post, Investigation Interview Questions to Determine Credibility, we reviewed the EEOC’s 5 factors to consider when determining statement credibility during investigation interviews. One of the toughest challenges to overcome during investigation interviews is the fact that witnesses may withhold or modify their responses to protect the subject- or the complainant and possibly even themselves. As investigators are often pressed for time when conducting internal investigations, they cannot afford to get hung up on determining who is correct in the “my story vs. their story” battle. We have compiled a list of simple tips and techniques investigators can use to determine investigation interview credibility.”

In order for a workplace investigation to be credible, investigators must deploy certain tactics to verify the accuracy of interview responses. In a previous post, Investigation Interview Questions to Determine Credibility, we reviewed the EEOC’s 5 factors to consider when determining statement credibility during investigation interviews. One of the toughest challenges to overcome during investigation interviews is the fact that witnesses may withhold or modify their responses to protect the subject- or the complainant and possibly even themselves. As investigators are often pressed for time when conducting internal investigations, they cannot afford to get hung up on determining who is correct in the “my story vs. their story” battle. We have compiled a list of simple tips and techniques investigators can use to determine investigation interview credibility.

Please note: It’s unlikely that the occurrence of a single deception indicator means that the interviewee is lying. Therefore, investigators should carefully observe for multiple deception indicators during interviews when determining statement credibility.

1. Consistent Statements

When asking questions related to the timeline of events involved in an incident, watch for inconsistencies or vague responses. This can be done by asking the interviewee to repeat or recall the order of events at different times throughout the investigation. Ask interviewees to go into greater detail about the incident-related events.  In the “Black Book of Lie Detection,” author Martin Soorjoo states that “when digging deeper, do so in an ‘interested’ manner rather than accusatory. Lying about detail requires a lot of thought and concentration.”

2. Body Language

Controlling physical actions is extremely difficult- hence the phrase “actions speak louder than words”. Pay attention to the physical tendencies displayed throughout the interview. Observe facial expressions and listen to the variations of pitch and tone in their voice. Body language that signifies lying varies across different cultures. Some of the common physical gestures exhibited by someone who is lying include: nail biting, touching their face- usually rubbing nose or covering mouth, avoiding eye contact, stroking the back of their neck, sweating, turning red in the face and fidgeting. In the “Black Book of Lie Detection,” author Martin Soorjoo states that “if an investigator believes the interviewee to be lying, don’t let on about it. Innocent people may become defensive if accused of lying and will demonstrate signs of stress through nonverbal and vocal cues- which can be mistaken as lying.”

3. Consider Your Own Bias

Investigators must remain neutral and refrain from making prior judgments in any investigation. Biases not only shape the attitude an investigator has towards the individual being interviewed, but can also influence the types of questions asked during investigation interviews. In the Business Management Daily article “Assessing Witness Credibility in Workplace Investigations,” they recommend bringing an additional investigator into the interview so that there’s an extra person to compare impressions and notes with. If personal bias is too difficult to overcome, consider asking an investigation manager to reassign the case to someone else to avoid sacrificing the accuracy of the investigation.

4. In the Eyes

Martin Soorjoo, author of the “Black Book of Lie Detection,” provides great insight into how an interviewee’s eyes can give them away. According to Soorjoo, an increased blink rate is often consistent with telling lies. Looking away and avoiding eye contact is tricky, as it may not always signal a lie is being told. When people lie, their pupils tend to dilate, which can be a useful indicator, as the body has no control over pupil dilation.

The free guide below includes an interesting “eye” test that can be used to decipher whether or not a lie is being told.

5. Incorporate Background Questions Into Interviews

At the beginning of an investigation interview, it’s beneficial to ask general background questions as a way to ease the interviewee into the environment. It’s likely that the person being interviewed will expect the questions to be based solely on the incident, therefore, background questions can be used to gauge the ‘normal’ responses and physical tendencies of the respondent. When investigators begin asking difficult, case-related questions it’ll be easier to accurately measure and monitor behavioral changes that indicate lying.

Investigators must be cautious during investigation interviews. People often mistake physical manifestations of stress as being indicators of lies being told. This sometimes happens to innocent people standing trial in a criminal case for a crime they didn’t commit. The irony is, the guilty defendant will have had plenty of time- sometimes years, to rehearse their lie. The innocent person will not have rehearsed because they are telling the truth and are scared because they have a lot to lose. Take this advice into consideration throughout ALL investigation interviews.

It seems to be that each week is busier than the last. Here are some of the things we blogged about this week- as well as some other pieces that caught our attention regarding internal investigation, human resources and ethics:

Monday:

• Blog Post- Investigating Workplace Bullying Allegations

“For many organizations, situations involving workplace bullying remain a growing concern. Whether the situation involves peers or superiors, all matters involving physical or mental bullying must be investigated promptly, with appropriate punishment administered. Like many forms of workplace harassment or discrimination, movements are being made to hold employers responsible for protecting employees from workplace bullying. In May, the Wall Street Journal published an article that discussed the signing of a bipartisan measure in the state of New York that would allow employees who have been abused in any form within the workplace, to place charges against their employer in a civil court. Following in the footsteps of the UK Bribery Act and US FCPA, the anti-bullying legislation proposed in New York states that employers may not be held liable in a workplace bullying case if they can provide sufficient evidence that a program is in place to prevent such incidents from occurring. ”

Tuesday:

• Blog Post- Best Practices in Supplier Responsibility: IBM

“IBM is committed to developing solutions to improve the transfer of information and providing businesses with solutions to simplify their business processes. In 2004, IBM became one of the founding members of the Electronic Industry Citizenship Coalition (EICC). IBM abides by- and helped to develop, the framework established by the EICC as guidance for their supply chain social responsibility program. In one of our previous posts, “The Importance of Supply Chain Ethics and Compliance,” I wrote about the importance of an ethical supply chain. As product parts are manufactured all over the world, it’s important that companies take responsibility to ensure all members of their supply chain act in a socially responsible manner. Companies are encouraged to review and implement their ethics, compliance and social responsibility policies within companies involved in the supply chain.”

Wednesday:

• Blog Post- i-Sight Investigation Software: Simplifying Case Management

“i-Sight Investigation Software is a customizable, centralized case management solution developed to help investigators, HR personnel and other members of a company’s investigative unit effectively manage case files. The above video provides a verbal and visual overview of how i-Sight Software works and the benefits it has to offer. Here are some of the topics discussed in the short video.”

Thursday:

• Blog Post- Global Reporting Initiative

“The Global Reporting Initiative is comprised of a very large group of experts who collaborate on the development of global standards for sustainability reporting. Joining the GRI is voluntary. With transparency and sustainability emerging as growing trends in the late 1990’s, the GRI was created to provide companies with a standardized sustainability reporting framework. Dissatisfied with the level of transparency in corporate reporting, the GRI works to make sustainability reporting mandatory, as opposed to voluntary. In a previous post, “Social Responsibility Reporting Best Practices: Allstate,” I discussed the application of the GRI reporting techniques at Allstate. The economic downturn has forced businesses and their leaders to make changes to their internal controls and business processes by adopting sustainable solutions.”