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Remediate and Enhance Your Internal Investigation Program (Part III of III)

An audit program of a company’s internal investigation function provides valuable insights for its internal investigation program and the company’s overall ethics and compliance program.  It is a critical part of ensuring that a companies speak up culture is adequately supported and promoted by an efficient and reliable internal investigation function.

A company learns a lot about its overall operations from its employee complaints and concerns – not just from a hotline but from walk-in and other types of compliance and concerns that are received.  To be sure, the investigation function provides a critical measure of what kind of concerns are being raised, how reliable are the concerns, and the nature of these concerns as part of the overall cultural fabric of the company.

From a narrow perspective, the internal investigation audit provides important insights on adherence to internal investigation requirements.  In response, the deviations may reflect that changes are needed in your investigation procedures.  However, it is more likely that weaknesses in the internal investigation program will require improvements in investigators who are not following established protocols.  Sometimes this may reflect that it may be difficult to comply with specific requirements, but more likely internal investigation audits reveal weaknesses in the quality and ability of investigators.

To respond, it may require assignment of additional investigators and staff, hiring of higher qualified investigators, and/or additional training of staff.  An internal  investigation program that is defective is typically a result of the three listed factors.  Part of the problem may occur when an intetrnal investigation program enlists the support of part-time investigators who have other responsibilities and conduct investigations as part of their overall duties.  In these circumstances, it is difficult to maintain quality and consistency when you do not have a fulltime, dedicated investigation staff.

An investigation training program is a great idea – however, it is really hard to make such training effective.  Often these training programs are conducted for a few days, and some may include actual exercises and training.  Even if crafted in the most effective way, it is hard to imagine that the participants will leave with effective investigative capabilities.  Frankly, an effective investigator is one who is a full-time professional with experience in conducting a large number of investigations.  Companies that rely on part-time investigators who have other responsibilities are likely to experience difficulties.

Aside from insights on an internal investigation program, the internal investigation audit results will provide information relevant to the company’s culture, operation of its ethics and compliance program, and overall employee morale.  An audit can reveal important trends within the company – for example, the audit may show that a specific actor or supervisor in a specific business unit has been mistreating employees, or that specific business unit has been the victim of several fraud schemes.

The audit results can confirm identified problems in the business, some of which can require remediation.  If a business unit has been the victim of several financial scandals surrounding theft or misuse of funds, the business may identify weaknesses in the unit’s financial controls, authorizations or existence of segregation of duty conflicts.  Sometimes the audit reveals the need for changes in specific policies or procedures.  The root cause analysis of numerous investigations may underscore an outstanding deficiency in existing policies and procedures that should be fixed. 

In the end, the investigation audit program if conducted annually can provide trend analysis and even confirm the success of remediation efforts.  The value of an investigation audit program is important to recognize and should be implemented as part of an overall testing and audit program.

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