The COVID-19 pandemic has presented corporate investigators with unique challenges that may exist way into the future. At the same time, it also presents new opportunities for corruption, theft, fraud, bribery and other types of criminal activity that may require a corporate investigation.
New risks for fraud, bribery and theft can stem from unvetted suppliers, employees working from home, supply shortages and many other areas of corruption. These are real crimes and they need to be investigated, even during a pandemic. Despite all these new challenges, you will still need to meet the goals and deliver on what is critical in a “normal” corporate investigation environment.
Rules for Corporate Investigations
Investigations of any of these or other crimes must adhere to the rules. The rules that apply have not changed even if the physical properties or addresses have. Internal investigations must be conducted, even if the way they are conducted is changing.
It is a good idea for top management to send a message to all employees and suppliers that you are still maintaining a strong fraud compliance and anti-corruption workplace during this pandemic and that any and all suspicious activities will be investigated.
Internal Investigation Training
This is also an excellent time to conduct corporate training. Teaching employees how to spot corruption, fraud, and other forms of illegal activities is important and may help in the event you may need to investigate a situation.
Virtual Investigation Interviews
If you must conduct interviews through tele-conferencing or video conferencing you may have to pay particular attention to facial expressions, vocal intonations and other “tells” as you won’t always be able to fully observe body language when assessing credibility or other dynamics. Not being able to read the normal signs due to technology, as well as possible connection issues or malfunctions, may make your job more challenging.
If you can make your witnesses comfortable it will help. Set them up with a laptop and headset if possible. Ask them to do the interview in an area where they will not be disturbed or distracted.
Need help conducting virtual investigation interviews? Watch our webinar on tips for conducting an effective video interview.
One other big challenge for you will be to establish authenticity and to make sure all your evidence is reliable prior to beginning any interviews. This includes emails, any documents, etc.
Conduct Due Diligence
Don’t forget to make sure your company conducts its due diligence on agents, suppliers, brokers, vendors or others that they conduct business with. The odds are good that you may be dealing with new supply chain vendors, third parties or others that you may not have dealt with in the past. Proper due diligence can go a long way in preventing the need to investigate.
Make sure that all employees know that your HR and your risk management departments are still operational and available if they need to report any suspicious or uncomfortable activities.
While this pandemic is active and especially when it is over, make sure your technology is up to date. This is crucial for investigation as well as determining if your risk management worked during this crisis. As an investigator it is still important for you to preserve your investigative integrity, confidentiality and independence throughout this challenging time.