After the internal report comes in and you have properly triaged the matter, you need to scope out and investigate it, promptly, thoroughly and with competent personnel. In the Evaluation of Corporate Compliance Programs - Guidance Document (2019 Guidance), provided these series of questions about your internal investigations:

Effectiveness of the Reporting Mechanism – Does the company have an anonymous reporting mechanism, and, if not, why See more +

After the internal report comes in and you have properly triaged the matter, you need to scope out and investigate it, promptly, thoroughly and with competent personnel. In the Evaluation of Corporate Compliance Programs - Guidance Document (2019 Guidance), provided these series of questions about your internal investigations:

Effectiveness of the Reporting Mechanism – Does the company have an anonymous reporting mechanism, and, if not, why not?  How is the reporting mechanism publicized to the company’s employees?  Has it been used?  How has the company assessed the seriousness of the allegations it received?  Has the compliance function had full access to reporting and investigative information?

 Properly Scoped Investigations by Qualified Personnel – How does the company determine which complaints or red flags merit further investigation?  How does the company ensure that investigations are properly scoped?  What steps does the company take to ensure investigations are independent, objective, appropriately conducted, and properly documented?  How does the company determine who should conduct an investigation, and who makes that determination? 

 Investigation Response – Does the company apply timing metrics to ensure responsiveness?  Does the company have a process for monitoring the outcome of investigations and ensuring accountability for the response to any findings or recommendations?

 Three key takeaways:

1. A written protocol, created before an investigation, is a key starting point.

2. Create specific steps to follow so there will be full transparency and documentation going forward.

3. Consistency in approach is critical. See less -