A Guide to Effective Internal Investigations

The call, e-mail, or tip comes into your office: An employee is reporting suspicious activity somewhere across the globe. That activity might well turn into a Foreign Corrupt Practices Act issue for your company. As the chief compliance officer, it will be up to you to initiate the process that will determine, in many instances, how the company will respond to misconduct as it relates to the FCPA. A company should have a detailed written procedure for handling any complaint or allegation of bribery or corruption, regardless of how that allegation is communicated. The mechanism could include the internal company hotline, anonymous tips, or a report directly from the business unit involved. This in-depth report is designed to provide compliance officers, audit executives, and other practitioners with all the steps needed to consider going forward.