Sundaraparipurnan Narayanan (snarayanan@skpgroup.com) is Director of Forensic Services for SKP Group in Mumbai, India.
The efforts of in-house investigation teams are integral to upholding an organization’s ethics and compliance (E&C). These teams must navigate through a maze of evidence to uncover violations and take appropriate disciplinary action. Larger E&C teams with hundreds of cases a year need to focus on efficiency, besides the pivotal responsibility of objectivity and independence in conducting investigations. With more cases, evolving case trends, and increased expectations of senior management and boards of directors, investigation processes need to be efficient.
E&C teams need to interface with multiple personnel and functions during an investigation. Lead time and efforts around such interactions are often cited as key hot spots for inefficiency. However, an E&C team may have inefficiencies associated with other factors also. Start to explore the potential for efficiencies in case handling by asking the following fundamental questions:
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Is there optimum efficiency at work?
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Are there efficiency gaps in small actions/activities undertaken by the team?
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Are there gaps associated with the use of technology?
Inefficiencies in case handling affect more than just the lead time for case closures. It affects the trust of the reporter in the system, the perception about the E&C function, as well as the feasibility of gathering tangible evidence.
Exposing inefficient areas
Games are among the most eloquent ways to explore or expose areas of inefficiency in any given process. Case-handling processes are no exception. A well-structured roleplay that resembles the actions and process steps associated with case handling not only helps the team to understand the context better, but also to identify the areas of inefficiency that can be addressed. The focus of such a game is to identify areas of improvement and process-efficiency opportunities as opposed to aspects that affect the qualitative factors.
We recently conducted a similar game-based engagement for a global multinational information technology company. The game was structured as a 10-step process that resembled the steps in case handling:
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Receiving a concern
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Understanding the concern
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Determining the approach
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Gathering information
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Reviewing the evidence
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Conducting relevant interviews
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Concluding the review and the report
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Communicating the recommended actions
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Tracking the implementation of actions
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Updating the portal on case closure
The game involved 13 members of the E&C team to play designated roles. The roles were:
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Reporter
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Investigators
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Functional representatives
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Compliance committee
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Subject and witnesses
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Information technology representatives
The multiple stages tested the decision-making capacities of the participants in finding an appropriate outcome, which came up during different steps of the game. Additionally, the game focused on the employees’ ability to stick to relevant and useful data while ignoring multitudes of additional information that might not be useful in the given context.
