An internal investigation is not really done before the writing of the final report, and obtaining the report is essential. Once done well, it can help an organization to go forward. If done wrong, it can create new problems.
Meric Bloch is the corporate director of investigations at Shriner's Hospital for Children in Tampa. He is also a director at Winter Compliance LLC. Many know him at the popular pre-conference workshop he gives each year to Al Gagné at the Institute of Compliance and Ethics. He and Al also lead the annual Internal Investigations Compliance Conference of the SCCE a two-day program focused on the inner workings of this critical element of an effective compliance program.
In this podcast, Meric shares his thoughts on writing the investigation report. The main topics covered include:
Writing the report starts with having a good plan of investigation that identifies the standard of business conduct that you are measuring against
The importance of including a consistent statement of what happened and why it happened
The report must do several things:
First, it must show that the organization responded in a timely and reasonable manner to the initial incident report.
Second, he must document the procedural steps of the investigation
Thirdly, it must indicate whether the allegation is well founded
Fourth, it must establish the factual basis for any post-investigation activity.
In some organizations, the report will include recommendations, but the question is how to do it?
The risks of going too far in the recommendations and saying that the direction "must" do something
The report should never include the findings of the law, the advisory rulings on how to contact the police, the assessments of the organization's responsibility for something
A survey report may allow the organization to improve internal controls to prevent a problem from recurring
The report can also be used as a shield in the event that a termination results in a lawsuit for unfair dismissal
The importance of including in the report the things that went well