Workplace Investigations
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Copyright - Workplace Investigations
Workplace Investigations | Author: Meric Craig Bloch | June 2013
Copyright © 2013 by the Society of Corporate Compliance and Ethics ®...
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Introduction
Workplace Investigations | Author: Meric Craig Bloch | June 2013
I am surprised that more people have not already written a book like this...
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Part I: Getting Started
Workplace Investigations | Author: Meric Craig Bloch | June 2013
For some companies, the strategic planning around the workplace investigations process is preparing for the day when the company receives a catastrophic misconduct allegation, such as the apocryphal whistleblower reporting that the CFO has been shredding financial documents. Otherwise, not enough thought is given to its role in the company’s operations. This shows both a poor allocation of company resources and a lack of imagination. If a critical incident occurs, the company’s response will take on a life of its own regardless of how much advance thinking tried to plan for it. If the situation happens a second time, the...
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Part II: Conducting the Workplace Investigation
Workplace Investigations | Author: Meric Craig Bloch | June 2013
Now to the “nuts and bolts” of a workplace investigation: An important rule is that you must “own” your investigations. You determine the manner in which the investigations will be conducted. Considering the goals, views and concerns of management is important, but you determine the investigation’s particulars...
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Part III: Other Investigation Issues
Workplace Investigations | Author: Meric Craig Bloch | June 2013
An overriding principle in conducting workplace investigations is “do no harm.” Problems have been made worse by poor investigations that make the investigation process look incompetent at best and as a cover-up at worst...
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Appendix A: Selling the Value of Workplace Investigations to Management
Workplace Investigations | Author: Meric Craig Bloch | June 2013
Before you can sell the business leaders on an improved approach to investigations, you will need to have a good professional relationship with them. There are many ways to build good relationships with senior managers. Some of them include:...
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Appendix B: Compliance & Ethics Issue Reporting and Response Policy
Workplace Investigations | Author: Meric Craig Bloch | June 2013
Appendix...
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Appendix C: Sample Mission Statement
Workplace Investigations | Author: Meric Craig Bloch | June 2013
The mission of the Workplace Investigations Unit (the “WIU”) is to provide the executive management of the company with a variety of coordinated investigation services. The goal of these services is to aid in accomplishing the WIU’s primary purpose—improving the quality, efficiency and profitability of business processes...
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Appendix D: Notification Matrix for Key Internal Departments
Workplace Investigations | Author: Meric Craig Bloch | June 2013
As part of the company’s commitment to an ethical workplace and to ensure that the company meets its legal obligations, the company requires colleagues and associates to report possible violations of the company Code of Conduct. The company, through the Corporate Compliance Department (“Compliance”), responds to these reports. Compliance also tracks these incidents and reports them to the Board of Directors...
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Appendix E: Notification of Investigation for other Key Internal Departments
Workplace Investigations | Author: Meric Craig Bloch | June 2013
Memo...
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Appendix F: Colleague Referral Guidelines
Workplace Investigations | Author: Meric Craig Bloch | June 2013
As part of the company’s commitment to an ethical workplace and to ensure that the company meets its legal obligations, the company encourages colleagues and associates, subject to local restrictions and guidelines, to report possible violations of business conduct. The company, through its Corporate Compliance department (“Compliance”), responds to these reports. Compliance also tracks these incidents and reports them to the Board of Directors...
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Appendix G: Guidelines for Outside Counsel
Workplace Investigations | Author: Meric Craig Bloch | June 2013
Memo...
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Appendix H: Management Notification of Investigation
Workplace Investigations | Author: Meric Craig Bloch | June 2013
Memo...
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Appendix I: Request for Interview
Workplace Investigations | Author: Meric Craig Bloch | June 2013
Memo...
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Appendix J: Request for Subject Interview
Workplace Investigations | Author: Meric Craig Bloch | June 2013
Memo...
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Appendix K: Instructions to Witnesses
Workplace Investigations | Author: Meric Craig Bloch | June 2013
This is a workplace investigation. It is a serious matter. You have been asked to assist us. We are trying to find out what happened here so we can advise management accordingly. We appreciate your time and cooperation...
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Appendix L: Personal Statement
Workplace Investigations | Author: Meric Craig Bloch | June 2013
Your Details...
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Appendix M: Final Investigation Report
Workplace Investigations | Author: Meric Craig Bloch | June 2013
Case Number:...
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Appendix N: No Retaliation Memorandum
Workplace Investigations | Author: Meric Craig Bloch | June 2013
Memo...
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Appendix O: Business Ethics Bulletin
Workplace Investigations | Author: Meric Craig Bloch | June 2013
As part of our commitment to an ethical workplace and to ensure that the company meets its legal obligations, the company requires colleagues and associates to report possible violations of the Code of Business Conduct. The company responds to these reports. From time to time, the lessons learned from an investigation are relevant to the operations of other business groups. We would like to inform you about the results of a recent investigation which may be of interest to you...
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Appendix P: Close-out with Reporter
Workplace Investigations | Author: Meric Craig Bloch | June 2013
Memo...
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Glossary
Workplace Investigations | Author: Meric Craig Bloch | June 2013
Business Unit means the internal business organization in which the incident arises. Notification is generally made to the immediate supervisor of the subject of the investigation...
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Sources
Workplace Investigations | Author: Meric Craig Bloch | June 2013
American Institute of Certified Public Accountants. The CPA’s Handbook of Fraud and Commercial Crime Prevention. Durham, NC: American Institute of Certified Public Accountants 2003...