You’re about to begin a complex investigation. What should you be thinking about? What should your first steps be? And what tricks of the trade are there?
To find out we spoke with Tech Data’s Jannica Houben (LinkedIn), Vice President Global Legal Transformation and Katarzyna Golonka (LinkedIn), Vice President Global Compliance. The two of them will be leading the virtual session “Advanced Investigations in Multi-National Companies” at the 2021 SCCE Compliance & Ethics institute, which takes place September 19-22, 2021.
A good investigation, they explain, needs to be properly scoped and be staffed with qualified personnel. In thinking who those people would be for your organization, they advise remembering to consider both the obvious and the subtle issues such as the languages you need on the team. And, of course, be sure your interviewers are well trained, not just eager.
Other things to think about right at the start:
- The legal expertise needed to understand reporting obligations, privacy and labor laws
- How enforcement authorities operate
- Whether there will be a need for IT and forensic resources
- Sector-specific knowledge
- Other expertise required such as in finance, sales, operations even SAP
One of the biggest decisions to make early is whether this is an investigation that is best handled using an internal or external team. Each has its own plusses and minuses. As they note in the podcast, an external team can bring in skillsets that you don’t have, including the often expensive and complex forensic resources. But, since an external team likely doesn’t know your culture as well as you do, they may miss the small things that an inside team wouldn’t.
They also discuss here the report that will come at the conclusion of an investigation. Documenting the steps you have taken is key, so much so that they believe if it isn’t documented it’s as if it never happened. It’s a part of demonstrating that the company took the issue serious and investigated thoroughly.
Make sure the report language is as concise and to the point as possible. The findings need to be reported objectively and accurately and, of course, state whether they allegations were substantiated or not.
Listen in to learn more and don’t miss their virtual session at the 2021 SCCE Compliance & Ethics institute.