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Investigating violations of your organizational code of conduct

Christine Davenport (christine.davenport@brooksrehab.org) is the Compliance Operations Manager at Brooks Rehabilitation in Jacksonville, FL.

Most organizations have a code of conduct, but have you thought about your code in relation to conducting investigations of issues that may have been reported via your hotline? The principles established in your code could be particularly significant when investigating an allegation related to human resources (HR). Although compliance professionals have a tendency to immediately turn to regulations (which is a good place to start), often your own internal organizational documents provide a lot of useful guidance as well.

As an example, if you had a complaint of bullying by an employee against another employee, how would you investigate this, and why would a compliance professional conduct the investigation rather than someone from within HR? It certainly seems a complaint of bullying would be a personnel issue. But what if the complaint came from an HR staff member about another HR staff member? In this situation, a compliance professional could provide a fair and impartial review. To determine the scope of the investigation, you will need to ascertain the precise nature of the complaint in order to identify exactly what you are investigating and who should conduct the investigation.

With an accusation as critical as bullying, you would want to move quickly to investigate the complaint and help resolve the matter. Having a preestablished game plan can assist in expediting the investigation and avoiding delays, thus demonstrating that your organization takes the matter seriously and that employees are protected at work.

This article will focus on the interview process of conducting compliance investigations. The article is not intended to cover every step involved in directing an investigation and will not review actions necessary should an investigation need to be conducted under attorney-client privilege.

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