Corruption Crime & Compliance

Corruption Crime & Compliance

Episode 91 -- How to Audit and Improve Your Internal Investigation Program

May 26, 2019

Companies are starting to understand that an effective internal investigation program is a critical function to promote a speak up culture. A company that has a dysfunctional internal investigation program will find it difficult to prevent and detect misconduct.

By contrast, a company that maintains an effective internal investigation program by adhering to its standard operating procedures, treating whistleblowers with respect and preventing any hint of retaliation, meting out consistent discipline, integrating investigation findings into compliance program enhancements and reporting on a transparent basis to employee about the performance of its investigation and discipline program – will advance the company’s culture and maximize potential reporting of code of conduct and legal violations.


To this end, companies have to commit to a multi-step review and improvement process for its internal investigation program. This is an exercise that is limited to reviewing the operation of the internal investigation program from the receipt of a reported concern to the conclusion of the investigation and handling of the results.

In this episode, Michael Volkov discusses how to audit and improve your internal investigation program.