Conducting Effective Internal Investigations: A Checklist for In-House Counsel
Every general counsel over the course of his or her career will face the need to conduct an internal investigation into events at the company. Many of these may be routine in nature, such as matters dealing with individual employees or human resources issues.
September 21, 2017 at 01:56 PM
16 minute read
Every general counsel over the course of his or her career will face the need to conduct an internal investigation into events at the company. Many of these may be routine in nature, such as matters dealing with individual employees or human resources issues. But at times the company may be required to examine issues affecting the core of its business, with potential serious impact on its financial performance or with regulatory exposure. The most serious issues—such as those involving the accuracy of the financial statements or misconduct of senior management—will be investigated at the board level. Even in board-level investigations, a prudent general counsel should take steps to help ensure the integrity and success of the investigation. A properly conducted investigation may help protect the company—as well as its in-house lawyers—from the potential fallout from instances of corporate misconduct. Here is a checklist of ten issues every general counsel should consider in any internal investigation.
1. Understand Your Role
The general counsel should play a central role in any internal investigation. Even in board-led investigations where independent outside counsel has been retained, the general counsel is likely to be a primary source of contact for the investigation team. This is an important function, and one that allows in-house counsel to facilitate and centralize the flow of information to the investigation team. By being in the middle of the information flow, in-house counsel can help ensure that requested materials are being provided promptly and that company employees are making themselves reasonably available to the investigators. It also allows the general counsel to track that various responsibilities related to the investigation (maitaining timeline, documenting process, controlling legal spend) are being met.
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