Internal investigations and fraud investigation policy
Produced in partnership with Noel Power of Dechert and Caroline Black of Dechert
Internal investigations and fraud investigation policy

The following Risk & Compliance precedent produced in partnership with Noel Power of Dechert and Caroline Black of Dechert provides comprehensive and up to date legal information covering:

  • Internal investigations and fraud investigation policy

Internal investigations and fraud investigation policy

    1. 1

      Introduction

      1. 1.1

        This policy sets out the responsibility of employees and management in relation to the investigation of fraud, bribery, facilitation of tax evasion and other business crime (together, “financial crime”), within [insert organisation name]. We will not tolerate any level of financial crime and are committed to protecting our assets and promoting honesty and integrity.

      1. 1.2

        [Insert organisation name] is committed to conducting its business in a transparent, honest and fair manner. All staff and third parties working on behalf of [insert organisation name] are expected to adopt the highest standards of accountability in promoting an ethical culture.

      1. 1.3

        Where financial crime is suspected, [insert organisation name] will commence an independent investigation of the allegations and remediate appropriately. This may include disciplinary procedures, dismissal and/or the provision of information to relevant criminal prosecution agencies. [Insert organisation name] will, in appropriate circumstances, seek to recover funds lost through financial crime committed or facilitated by employees.

      1. 1.4

        Common scenarios that may trigger an investigation include:

        1. 1.4.1

          an individual raising a concern internally via a whistleblowing hotline or otherwise (whistleblower);

        1. 1.4.2

          a response to a regulatory or criminal agency demand;

        1. 1.4.3

          part of due diligence in advance of a merger or acquisition;

        1. 1.4.4

          a civil litigation claim;

        1. 1.4.5

          an internal or external auditor’s report;

        1. 1.4.6

          media reports;

        1. 1.4.7

          an external allegation, eg from a customer/client or counter-party.

    1. 2

      Scope of this policy

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