Organizational investigations program. Most organizations have investigations occurring, whether as part of a structured and thought-out formal program by trained personnel or as done on the front line by managers who hear issues of concern. Therefore, it is vital to identify the current personnel who undertake organizational investigations and get their input, buy-in, and alignment as a formal organizational investigations program is created.
Organizational Investigations Program
Furthermore, organizations should consider any change management needed to move from the current state to an implemented investigations program with ethics and compliance oversight.
There are several basic steps to adapt as organizations consider and develop an organizational investigations program:
- Identify the organization’s information points and possible sources of information for issues and complaints of all types;
- Identify the framework of the investigation currently in place;
- Conduct a skills assessment of those who have or could potentially be asked to conduct investigations and develop or identify a training program for internal investigators;
- Design or evaluate the framework of the investigation, with an eye to the organization’s risk profile;
- Consider the organizational philosophy and strategic goals regarding investigations and the rights and expectations of witnesses and investigators;
- Consider with other key risk-management functions whether any additional policies or procedures are needed and develop accordingly with any necessary training modules or implementation support;
- Schedule a timeline for the implementation of the framework of the investigation considering existing investigative activities (and the input and buy-in of those stakeholders) and organizational culture with change management in mind; and
- Implement the designed organization structure, measure and monitor effectiveness, and adapt to changes in the organization and environment as needed.
In addition to these steps, there are a few other matters to consider in creating an investigations program, including the need for an investigations case management system, the issues of attorney-client privilege, the possibility of the need to report an issue to a government agency, and global issues.
What Are The Organization’s Information Points?
Employees always have information about where the issues and systems breakdowns are. The challenge is retrieving and accurately harnessing that information. Effective Ethics and Compliance functions tap into the organization’s many information sources and supply employees and others a safe place to share important information about suspected problems and issues. The organization should have a framework in place to identify which information and matters and should be investigated and how such investigations should be managed.
Therefore, the first step in organizing an investigative framework is to identify the various information points in an organization, which are the people and departments that are most likely to receive complaints and reports. The Ethics and Compliance function should create or utilize the many paths to reporting and encourage that reporting. Finally, the organization must determine how and where to handle the different types of investigations. Organizations should consider, based on their size and organizational structure, and where there are information points for employee complaints.
Regardless of size, most organizations conduct investigations, whether as part of a structured and well-thought-out formal program by trained personnel or on the front lines by managers who hear about issues of concern. As a result, identifying current personnel who conduct organizational investigations and obtaining their input, buy-in, and alignment is critical as you seek to create a formal organizational investigations program. Additionally, organizations should consider any change management required to transition from the current state to a fully implemented investigations program with ethics and compliance oversight.