We cannot deny the changes and additional requirements. Therefore, I am convinced that it needs some reflection and review of the investigations process too.  

The use cases and examples of the last few months demonstrated a wide variety of maturity level of the teams conducting investigations.

And by saying that, these different set-ups and processes were raised by one of the peers of the Corporate Integrity Circle a few weeks ago.  

It became obvious how different the maturity levels are in terms of 

• Team set up 
• Investments done or especially hold back (in the ongoing financial year) 
• Missing budgets for the future  
• Lack of training opportunities 

With the knowledge we all earned – which is supported by different studies – it is crucial that the have process and tools in place which supports us on our mission of fighting against fraud and bringing facts to the table.  

Professional and adapted to the individual investigation processes are much more effective for all involved parties than ad-hoc. And that is, was we need to have for our internal and external clients.   

Therefore, we need a high maturity level of adaptability – also when it comes to our own investigation processes.

And here I come back what I have prayed for so many years and still believe in: Internal Investigations need a sponsor! 

This does not mean that the sponsor must be directly involved but should understand the importance and stand in for it.  

If you reflect your situation 

• Are you a sponsor when it comes to internal investigations? 

Or if you are the one responsible for the investigations:   

• Do you have a sponsor?  And if so: how effective is it and what could be improved? 

Especially during crises which are not inherently fraud or non-compliance incidents it is even more important to have such a sponsorship on top level. 

Because, as we have learned, with an external crisis like the pandemic, the focus shifts away. The additional risks based on the new situation are often overseen.  

Planning

With the Investigation planning we have the two level 

• Strategical 
• Operational 

 Switching to a complete remote planning process will need additional time spent on the set-up as such. 

Some of the most important aspects are: 

Information and Data channels 

• How can we ensure that the entire team are informed? 
• What is the internal protected and secured platform to share internal information? 
• Do we have a project management tool in place – of course protected and secured – which fulfils the needs of the remote work? 

I would expect that most of the global investigation teams already have most of the above tools in place. 

What it often needs is to really use it. This means, everybody has to commit to use the identified and implemented tools with the dedicated functionalities. With incomplete information an effective investigation management is not possible.

Setting up the workflows for remote team need even more discipline from all the involved parties.  

Investigation teams: 

• are they already used to work remotely?  
• Do we have new members or ones not used to work remotly? How can we integrate them?  

Goal must be, that the teaming receives most attention – especially in this kick-off and planning phase 

Technology and infrastructure: 

• How is the actual set-up?  

The highest security level is not discussable at all and for the teams already working remotely “state of the art”.  

• What is needed in addition and how fast could that be delivered?  

I know the time of ordering and receiving hard - and software was not an issue up to March 2020. But these days it could be crucial 

Data collection: 

We all know that there are certain data we must collect during an investigation which are not all just electronically available. I am talking about the images we need to have from specific devices. Like notebooks, desktops and mobile devices. 

• What is the process to obtain this important confidential information with as less as possible physical interactions?  
• Are there different levels which could be set up to a standardized process? 

For the eDiscovery process I would not expect a big pivot to the normal workflow we already have in process.  

Also the review and report writing process – if the workflows with the team and information exchange are well implemented – can be conducted as the investigators are used to.  

Interviews: 

Yes, here we have to get in touch with people to find additional evidence and information supporting the entire investigation.  

We all learned how to perform during virtual meetings via tools using cameras and microphones. Of course, documents can be uploaded and shared between the parties.  

But for a professional interview where it is necessary to observe the interviewees’ reaction and assess the credibility of those – verbally and non-verbally – physical interview should still be the preferred options.  

It makes a difference when the environment, setting, sound and paces as well as the demonstration of data can be used to find the answers. The interaction between interviewees and interviewer often let the entire investigation move a big step forward.  

So please, be careful when you plan the interviews. Rather wait – if possible – instead of having all interviews done remotely.  

KEY MESSAGES

A lot of teams in our industry easily adapted to the new circumstances. Some of them did not even have to as they also conduct global investigation in a remote setting for years. 

Others are still on their way and with the before-mentioned key elements of 

• Data / Information channels 
• Team 
• Technique & Infrastructure 
• As well as with the last but most important discipline of 
• Interviews 

I am convinced that the necessary maturity level can be achieved.  For all of us.

EPISODES' REFLECTION

Without a team which exactly knows about the new process, the expectations and tools available – your investigation will not be successful. 

Same for the interviews: Here you have the biggest leverage to find the smoking gun. The interaction between humans. 

Of course supported by technology.

Let me come back to the questions which could be used for you to analyse the current situation about the sponsorship for internal investigations:  

• Are you a sponsor when it comes to internal investigations? 

Or if you are the one responsible for the investigations:   

• Do you have a sponsor?  And if so: how effective is it and what could be improved?

THANK YOU FOR SHARING, SUBSCRIBING AND REVIEWING

Thank you for joining me on this episode of THE HUMAN FACTOR – Corporate Integrity Matters.

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