Internal investigation is a professional fact-finding process, initiated by or for an organization, to establish facts in relation to alleged or suspected wrongdoing, misconduct or noncompliance. There are times when organizations of different kinds and sizes may need to conduct an internal investigation, and this may be due to situations that arise that demand immediate action. Such situations could include internal misconduct, irregularity, compliance violation, and alike. An internal investigation done properly may help organizations mitigate the impact of the potential consequences, and thus gain more control over the situation. With the insight gained through an investigation, the organization can then devise timely corrective actions to address these violations.
ISO (the International Organization for Standardization) has recently published a comprehensive guidance on ‘Internal investigations of organizations’ – ISO/TS 37008. The standard document provides guidance on internal investigations within organizations, including:
- The principles.
- Support for investigations.
- Establishment of the policy, procedures, processes and standards for carrying out and reporting on an investigation.
- The reporting of investigation results.
- The application of remedial measures.
The standard also states that it applies to any organization, no matter what its type, size, location, structure or purpose is, and that it should be adapted to fit each organization’s needs, making the required changes to each corporate compliance management system.
What is it?
- It is a technical specification (TS) published by the International Organization for Standardization (ISO) regarding the internal investigations.
- It provides guidance on the principles, policies, and procedures for conducting internal investigations of organizations.
- It covers the entire investigation process, from planning and preparation to reporting and follow-up.
- It is applicable to any type of organization, regardless of size, sector, or nature of the investigation.
Why is it important?
- It helps organizations to establish and maintain an effective and consistent internal investigation system.
- It helps organizations to comply with relevant laws, regulations, and ethical standards.
- It helps organizations to prevent, detect, and respond to misconduct, fraud, corruption, or other irregularities.
- It helps organizations to protect their reputation, assets, and stakeholders.
Main contents
An investigation should follow five principles: (independent; confidential; competent and professional; objective and impartial; legal and lawful). These principles should guide every step of an investigative process. Investigators need to consider these principles when making a significant decision.
Pre-investigation stage: good preparation is essential to achieve a satisfactory outcome of the investigation. Preparation involves making a plan for the investigation that defines the members of the investigative team and the extent of the investigation. Efforts to secure evidence, safeguard witness and avoid interference are prioritized.
Conducting the investigation: collecting and analyzing documents and interviewing people are the two main components of an investigative process. Collecting documents involves finding the relevant documents and examining them scientifically. Interviewing people also seeks to generate helpful information for examination purposes. Both of them will help to write the final investigative report.
Post-investigation stage: the final investigative report is the basis for the actions taken after the investigation. These actions mainly involve finding solutions for the violations that caused the investigation. Possible solutions may include changing or improving the organization’s current compliance structure. The organization’s top management should make important decisions at this stage, such as whether to report the violations to the relevant authorities; whether and how to communicate with external stakeholders; what solutions to implement to deal with the situation.
What are the main benefits of it?
- It provides a comprehensive and practical framework for conducting internal investigations.
- It promotes a culture of integrity, transparency, and accountability within organizations.
- It enhances the credibility, reliability, and quality of internal investigation outcomes.
- It facilitates the cooperation and coordination among internal and external parties involved in internal investigations.
In conclusion, this new ISO emphasizes the importance of management support for a successful internal investigation. This support may be manifested by adequate resources provided for the investigation and evidence of the management’s adherence to the key principles that should guide investigations.
The introduction of the ISO 37008 will probably affect how internal investigations are carried out. It may also encourage companies to examine their internal investigations policies and practices to comply with this global standard. In the near future, ISO 37008 is expected to become the global reference for internal investigations, and companies seeking to maintain a high standard of corporate governance should adopt its guidelines.
Yazı: Salih Aksu Compliance Assurance Partner – AstraZeneca
Note: The opinions and comments in the articles belong to the author or authors and do not reflect the opinions of the Ethics and Reputation Association on the subject.
