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Ethics and Standards Review

Internal Investigation Framework

Standard Committee

Purpose
This framework establishes a standardized approach for conducting internal investigations to ensure a fair, consistent, and thorough process. It safeguards the integrity of organizational procedures, accountability, and confidentiality.



0. Confidentiality

  • Confidentiality Guidelines:
    Confidentiality is critical for protecting all involved parties and ensuring the investigation’s integrity. Information regarding the investigation should only be accessible to the designated review team.
    • No information may be shared outside the review team unless expressly authorized.
    • If confidentiality is compromised, the audit team may remove the affected member's testimony or declare the review invalid.
  • Data Handling Protocols:
    All documentation and records should be securely stored with restricted access to authorized personnel only.

1. Initiation of Investigation

  • Trigger for Investigation:
    Investigations may be initiated in response to:
    • Reported incidents (e.g., policy violations, misconduct, safety concerns).
    • Identified risks or potential process failures.
    • Management observations or flagged audit results.
  • Authorization Requirements:
    Investigations require authorization from two or more board members who are not implicated in the incident to maintain objectivity.
    • If all board members are implicated, a vote may appoint an internal audit lead or approve a third-party audit for impartiality.

2. Scope and Objectives

  • Define Scope:
    Clearly define the scope of the investigation, including specific allegations, individuals, processes, or policy areas to be addressed. Ensure alignment with organizational policies and standards.
  • Set Objectives:
    Identify what the investigation aims to achieve, such as:
    • Uncovering relevant facts and establishing timelines.
    • Determining the root cause of the incident or behavior.
    • Identifying gaps in policies or procedures.
  • Timeline:
    Set a realistic timeline for completing the investigation and communicate this to relevant stakeholders.
  • Scope Document:
    Develop a formal scope document detailing the objectives and limits of the investigation.
    • This document, prepared by the investigation team, must be finalized before the investigation begins.
    • If the investigation scope changes, an amendment to the document should be submitted.
    • The scope document should contain only essential information and be prepared for press-level scrutiny, without confidential data.

3. Investigative Team Selection

  • Team Composition:
    Choose team members based on relevant expertise, impartiality, and authority. Representatives from essential departments may be included.
  • Conflict of Interest Check:
    All team members must declare any conflicts of interest to ensure objectivity.
  • Roles and Responsibilities:
    Assign specific roles, such as lead investigator, interviewer, and evidence manager, to maintain clarity and avoid duplication.
    • Team members may assume multiple roles, depending on team size and investigation complexity.

4. Planning the Investigation

  • Background Research:
    Gather initial information relevant to the incident, such as prior incidents, records, or applicable policies.
  • Investigation Plan:
    Develop a detailed plan that includes:
    • Key activities like document reviews and interviews.
    • Sources of information and data to be examined.
  • Legal and Compliance Considerations:
    Ensure all steps comply with local laws, labor regulations, and internal policies. Organizational policies do not supersede anylocal legal requirements.

5. Evidence Collection

  • Document and Data Review:
    Collect all pertinent records, including emails, reports, logs, and any process documentation.
  • Interviews and Statements:
    Interview involved individuals and relevant witnesses.
    • Use open-ended, unbiased questions and document all responses.
  • Preservation of Evidence:
    Securely back up physical and digital evidence to prevent tampering or data loss.
    • Cloud backups should be maintained securely.
    • Any loss of information may lead to a formal warning or removal from the review team, depending on the severity.

6. Analysis and Evaluation

  • Review and Analyze Evidence:
    Carefully evaluate all evidence to confirm facts, timelines, and compliance with relevant policies.
  • Identify Gaps and Causes:
    Pinpoint procedural or operational gaps that may have contributed to the issue.
  • Accountability and Impact Assessment:
    Based on findings, assess the accountability of individuals and the organizational impact of the incident.

7. Documentation and Reporting

  • Prepare a Detailed Report:
    Summarize findings, analyses, and recommendations, including:
    • Investigation overview.
    • Key evidence and factual conclusions.
    • Accountability determinations, if applicable.
  • Recommendations:
    Provide actionable recommendations, which may include:
    • Disciplinary actions.
    • Policy or procedural improvements.
    • Staff training or awareness initiatives.
  • Review and Approval:
    Submit the report to the board for review, approval, and further action.

8. Communication of Findings

  • Internal Communication:
    Share findings with relevant parties while respecting confidentiality.
    • Major findings should be communicated via email with all team members cc’d.
    • Communication between team members should occur within a designated group chat involving the majority of the team.
    • Unauthorized communication outside the group chat is subject to disciplinary action.
  • Feedback Loop:
    Provide each individual interviewed with a transcript of their statements.
    • Individuals have 24 hours to request amendments or redact sensitive information before the document is finalized.

9. Post-Investigation Actions and Follow-Up

  • Implement Recommendations:
    Collaborate with relevant departments to implement any recommended actions and monitor completion.
  • Track Progress and Effectiveness:
    Regularly review the effectiveness of implemented changes to address any new issues promptly.
  • Policy Review:
    Update investigation policies and procedures as necessary to reflect insights gained and best practices.

10. Documentation and Record-Keeping

  • Record Retention:
    Securely retain all investigation documentation per organizational policy and relevant legal requirements.
  • Confidentiality and Access Control:
    Restrict access to investigation records to authorized personnel only, ensuring compliance with confidentiality protocols.


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