Whether an allegation arrives through a hotline, an auditor or a regulator, the first days set the course of an investigation. This checklist is general and should be adapted to the facts and jurisdictions involved.
- Identify who oversees the investigation and avoid conflicts
- Preserve documents and devices, and suspend routine deletion
- Consider privilege at the outset and document the structure
- Decide who must be told: auditors, insurers, regulators, the board
- Protect whistleblowers and prevent retaliation
Early advice from counsel experienced with the relevant regulators can help a company decide whether and when to engage with them.
This publication is general information, not legal advice. It may not reflect later developments. Contact a lawyer about your circumstances.