Bass, Berry & Sims attorney Thad McBride co-authored an article for Compliance & Ethics Professional magazine outlining best practices for conducting effective internal compliance investigations. Thad co-authored the article with Kate Garfinkel, Vice President and Chief Ethics & Compliance Officer at Alcoa Corporation.

As the article states, “A strong internal investigation process can make the difference between identifying and addressing a problem early on or letting it fester into an issue that becomes a legal liability and reputational crisis … Internal compliance investigations and reviews, when conducted in a confidential and professional manner, ensure that a company can adequately address compliance issues.”

The article details several key components of an internal compliance investigation, including:

  1. Developing an investigation plan
  2. Preserving, collecting, and reviewing data
  3. Conducting interviews
  4. Reporting and remediation

Thad and Kate acknowledge that no two internal reviews will be the same. But Thad and Kate also emphasize that “there are steps that should be followed in every review to maximize the chance that the review will satisfy legal obligations to investigate and respond to allegations of misconduct. In the current enforcement environment, and to promote a culture of compliance, it is important to be able to conduct a careful, properly scoped internal review.”

The full article, “Internal Compliance Investigations: More Important than Ever,” was published in the April 2018 edition of Compliance & Ethics Professional magazine and is available in the PDF below. Compliance & Ethics Professional magazine is a publication of the Society of Corporate Compliance & Ethics.