Workplace Investigations

  1. Copyright - Workplace Investigations

    Workplace Investigations  | Author: Meric Craig Bloch  | June 2013 

    Copyright © 2013 by the Society of Corporate Compliance and Ethics ®...

  2. Introduction

    Workplace Investigations  | Author: Meric Craig Bloch  | June 2013 

    I am surprised that more people have not already written a book like this...

  3. 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...

  4. 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...

  5. 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...

  6. 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:...

  7. Appendix B: Compliance & Ethics Issue Reporting and Response Policy

    Workplace Investigations  | Author: Meric Craig Bloch  | June 2013 

    Appendix...

  8. 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...

  9. 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...

  10. Appendix E: Notification of Investigation for other Key Internal Departments

    Workplace Investigations  | Author: Meric Craig Bloch  | June 2013 

    Memo...

  11. 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...

  12. Appendix G: Guidelines for Outside Counsel

    Workplace Investigations  | Author: Meric Craig Bloch  | June 2013 

    Memo...

  13. Appendix H: Management Notification of Investigation

    Workplace Investigations  | Author: Meric Craig Bloch  | June 2013 

    Memo...

  14. Appendix I: Request for Interview

    Workplace Investigations  | Author: Meric Craig Bloch  | June 2013 

    Memo...

  15. Appendix J: Request for Subject Interview

    Workplace Investigations  | Author: Meric Craig Bloch  | June 2013 

    Memo...

  16. 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...

  17. Appendix L: Personal Statement

    Workplace Investigations  | Author: Meric Craig Bloch  | June 2013 

    Your Details...

  18. Appendix M: Final Investigation Report

    Workplace Investigations  | Author: Meric Craig Bloch  | June 2013 

    Case Number:...

  19. Appendix N: No Retaliation Memorandum

    Workplace Investigations  | Author: Meric Craig Bloch  | June 2013 

    Memo...

  20. 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...

  21. Appendix P: Close-out with Reporter

    Workplace Investigations  | Author: Meric Craig Bloch  | June 2013 

    Memo...

  22. 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...

  23. 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...