How to plan and conduct an internal investigation
Produced in partnership with Noel Power of Addleshaw Goddard
Practice notesHow to plan and conduct an internal investigation
Produced in partnership with Noel Power of Addleshaw Goddard
Practice notesAn internal investigation is a legal process undertaken by an organisation (with or without outside counsel) to review and identify facts relating to a specific allegation, concern or misconduct and remediate potential irregularities.
What sort of events may trigger an investigation?
Common scenarios that may trigger an investigation include:
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an individual raising a concern internally via a whistleblowing hotline or otherwise (whistleblower)
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a response to a regulatory or criminal agency demand
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part of due diligence in advance of a merger or acquisition
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a civil litigation claim
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an internal or external auditor’s report
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media reports
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an external allegation, eg from a customer or counter-party
Why conduct an internal investigation?
Internal investigations are an important process in establishing the factual circumstances of a particular event or series of events in a way which best protects the organisation and the board. The overriding aim should be to determine the facts and mitigate any legal, regulatory and reputational outcomes, ie:
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establish the relevant facts to enable the board
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