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Three avenues of multiparty investigations

Bailey Naples (baileynaples@berkshirefarm.org) is a Director of Risk Management and Corporate Compliance Officer for Berkshire Farm Center and Services for Youth in Canaan, New York, USA.

Investigations produce a number of challenges, which become more numerous and difficult when two parties need to investigate the same or closely related allegations. When the need for an investigation arises that requires the participation of an outside entity (or a separate internal entity), your mutual investigations can be conducted through three fundamentally separate manners.

The first way is running “concurrent and mutual” investigations, where the interviews and process of investigation is done together. The two investigating parties work together, interview together, look at the same documentation, share their internal leads, etc. They typically produce separate reports, but they share the same goals and same concerns and often the same recommendations.

The second way is running “separately simultaneous” investigations where the two parties run separate investigations, including separate interviews, and write their separate reports. They may meet to share and discuss their reports, but their goals and focuses typically result in different recommendations.

The third and final way is “separately spaced” investigations. In these investigations, the compliance investigator is required to wait until the third party completes their investigation, and only once the third party produces their report may compliance proceed with an internal investigation.

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