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The ABCs of an effective investigative process: Part 1

Ahmed Salim (ahmed.salim@irhythmtech.com) is Director of Ethics and Compliance with iRhythm Technologies in Lincolnshire, IL. David M. Rapasadi (drapasadi@medline.com) is Senior Compliance Specialist at Medline Industries Inc. in Northfield, IL. Palak Desai (pdesai14@mail.depaul.edu) is a student at DePaul University College of Law in Chicago, IL.

Investigations are essential to running an effective compliance program. A well-defined investigation sets forth how individuals report potential compliance concerns and mentions any remedial measures once the investigation has concluded. These practices also create a culture of compliance within an organization by assuring employees and surrounding community members. The organization’s commitment to corporate integrity and creating a thorough investigative process can be challenging and exhaust a number of limited resources. In order to create a strong investigative process, an organization should look internally to determine what processes they have in place and whether any new processes should be implemented.

The strength of an effective investigation is determined by breaking the process into two parts: (1) receiving/triaging a concern and conducting the investigation and (2) benchmarking and reporting.

In this two-part article, we will illustrate how to implement a well-defined investigative process. Our mission is to provide compliance departments looking to adopt their own processes with a road map of how to build a strong and reliable investigation system.

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