Synopsis: Helping firms (specifically audit committees) investigate allegations related to the Dodd-Frank Whistleblower Program
Focus: 10 Tips on handling an investigation
1) Prepare investigative protocols
- · These preparations can ensure that you operate within pre-established bounds and establish roles and responsibilities for various company departments.
2) Select your team
- · As much as is possible, align your resources in advance.
3) Respond promptly and prudently
- · A prompt response sends the message that you are handling each tip with the attention it deserves and may prevent potential information providers from going outside the company to report allegations of wrongdoing.
4) Remember that an investigation is NOT an internal audit
- · Among other things, investigations 1) have a different purpose, 2) may apply techniques that are not cost-effective in typical internal audits and 3) place greater emphasis on interviews and public records.
5) Balance diligence with efficiency
- · Two helpful techniques are approaching an investigation in phases and sorting data by function/usage.
6) Control the flow of information
- · Determine in advance who should receive what types of information – breaches can be catastrophic.
7) Navigate global differences (as needed)
- · Be cognizant that, among other things, gaining trust from witnesses may require different approaches in different cultures.
8) Anticipate the unexpected
- · Be mindful of handling, among other things, potential employee resignations, an expanded scope and/or additional parties to the misconduct.
9) Consider not only what is said, but how it is said
- · As noted in Globe University’s Fraud Examination course, nonverbal cues such as refusing to answer questions, repeating questions (i.e. stalling) and/or responding to questions with questions may be just as telling as what is uncovered in an interviewee’s testimony.
10) Learn from your experiences
· Much can be identified during an investigation, including potential internal control weaknesses and changes that can be made to your company’s ethical culture.
From Deloitte’s Audit Committee Brief: “Internal Investigations: 10 Ways to Prepare in Advance”