Our Approach to Compliance and Ethics Investigations
The ILPartners Approach is to first listen to the client describe the current situation or allegation that has been reported and how the client feels ILPartners can help with performing its investigation. After listening, ILPartners will collaborate with the client to begin development of the investigative plan. ILPartners will ask the client questions about items such as whether or not there is relevant historical information, how the desired investigation can be coordinated among internal and/or outside work functions, and whether or not the compliance and ethics investigation will be done with legal privilege. Although ILPartners can take initiative in performing any required investigation, it is imperative that ILPartners have an identified ‘Point of Contact’ to coordinate with in developing and carrying out the investigation plan.
Three of the most important reasons for a client to consider having an outside resource such as ILPartners perform compliance and ethics investigations for it are:
- Compliance and Ethics Investigations can be very resource and time demanding and often a company does not have full time staff available to respond to a needed investigation in prompt and timely manner.
- Often, although an internal resource may exist and is available, the perspective used in developing the investigative plan is from the lens of looking at the issues from within the company rather than taking an outsider’s, or independent look, at how to best investigate and resolve the issues based on the findings.
- Sometimes through no fault of their own, an internal investigator has a ‘Conflict of Interest’ with those who will be part of the investigation. These potential conflicts could come from a number of different sources such as personal friendships or organizational reporting relationships. In some of these cases, clients may wish to use an independent investigator.
In all cases, ILP wishes to collaborate with the client for an effective, efficient, thorough and complete, and timely investigation. Although ILPartners has its own protocol or guidelines for compliance and ethics investigations, ILPartners will work with any guidelines or protocols called out or required by the client. One of the most important aspects of all compliance and ethics investigations is that of holding and guarding confidential information. ILPartners will work with the client to accomplish this to the very best of their ability, and this begins with a non-disclosure agreement between the client and ILPartners.
The goal of any sound compliance and ethics investigation is to establish the facts of what has been reported, of that which has allegedly occurred per the reporter. A typical investigation will include: reviewing documents, interviewing employees and/or others, and analyzing data such as events, timelines and motivations for certain behaviors. In the end, ILPartners will collaborate with the client to draw conclusions and recommendations based on the investigative findings. ILPartners will professionally document every part of the investigative proceedings, from interviews and analysis, to recommendations.