Introduction
This guide is provided to assist corporations with establishing and directing corporate internal investigations. This guide anticipates the use of outside legal counsel and professional investigative experts, who will provide necessary, independent, third-party objectivity. Of course, this guide can be adapted and modified for use in many types of corporate internal investigations.
A General Guide to Organizing an Internal Investigation
Before a crisis occurs, companies should have a crisis management plan in place. This plan should be developed with the assistance of legal counsel, a designated investigator and a security consultant.
With or without these preparations, investigative consultants should be called immediately at the time of a crisis. Professional investigators can provide emergency response by securing company documents and computer files as well as the physical offices, protecting the company from further damage. These specialists can also begin investigating the actual events of the crisis, information that can be used later by legal counsel.
With these initial actions in place, the following steps may be considered as part of company response:
- Develop as much information as possible regarding the situation or accusation through routine channels.
- Define problem area.
- Determine legal counsel and an investigative firm to be involved and establish attorney-client and work product privilege parameters.
- Establish a network of key individuals to be involved in the investigation and methods of contact for each.
- Review documents, accusations and investigative strategies.
- Develop a crisis team to prepare press releases, and question-and-answer responses for the media if necessary.
- Conduct approved investigative strategies.
- Using the results of the investigation, take necessary action to resolve problem areas.
- Provide guides for employees and notify key customers and suppliers, if necessary.
- Find a secure location for business records and computer files and relocate them.
- Establish and reconstruct security of the corporation’s computer facility and mainframe computer system, if warranted.
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