EXECUTIVE ENGAGEMENT AND RESPONSIBILITY DURING INTERNAL INVESTIGATIONS
Internal corporate investigations are critical to addressing and mitigating compliance risk for all organisations, and there may be greater scrutiny on how internal investigations are managed for companies operating in industries that are highly regulated.
When done properly, an investigation can help identify risks and remediate them. In some situations, identified concerns involve wrongdoing by senior leadership, material financial impact to the bottom line, require organisational restructuring, affect employee culture and morale, and have reputational consequences – the list goes on. All of which inevitably require strong engagement with executive leadership and C-suite level personnel.
Obviously, given the potential impact that the situations highlighted above could create, it stresses the criticality for executives to answer the following: how should we be involved and what is our responsibility during an internal investigation?
Every business operates differently and faces varying risks, but addressing the question above relies upon a fundamental principle. Companies should commence internal investigations that are led by a qualified internal investigation team and maintain a robust investigations framework that underscores the importance of independence and confidentiality. Having the right team and structure in place helps ensure that from the onset there is an increased probability that significant risks will be identified, the right plan developed and the appropriate remediation implemented. Furthermore, this investigative framework must consider when executive leadership should be involved, how they should be involved, and what is their responsibility during an investigation.
Oct-Dec 2022 Issue
Patterson Companies, Inc.