VIEW FROM THE FRONT LINES
by Meric Craig Bloch, CCEP‑F, CFE, PCI, LPI
Too many investigations begin either as a mad scramble to learn every possible fact or with a lackadaisical
approach that means the investigator is
gathering evidence in search of an allegation.
Either way, the investigation becomes
inefficient, sloppy, and disruptive and
generally wastes limited resources.
The investigation result is also poor
This is often the result of using
only the hotline report to determine the
scope of the inquiry. The investigator
has overlooked the important step
of assessing the available information to
determine the appropriate resolution steps.
An investigator generally has wide latitude
to define the scope. For most organizations,
the report need only be resolved (rather
than ignored or treated simply as a disposal
problem). A decision has to be made regarding
the objective of the investigation.
An investigation objective can usually be
summed up in one sentence and hints at the
post-investigation goals of the process. An
investigation objective is nothing more than
the answer to a simple question: What does the
investigation need to prove? You can investigate
more efficiently and effectively if you identify
from the outset the precise allegation you
intend to investigate.
This doesn’t sound especially profound, but
it’s a simple step that’s frequently overlooked.
Grab a cup of coffee, and spend a few moments
thinking about the information you have so
far. Does it look like employee misconduct or
a possible crime? Does it look like a specific
company policy was violated, or is it something
more generic like poor management supervision?
Does it appear that only a rogue employee
is involved, or could it be a perfect storm of
unacceptable factors that conspired to create
Once you’ve finished your coffee and
answered these questions (at least for now), you
should then identify the component elements
of the alleged wrong. For example, if your
investigation objective is to determine whether
Janet violated the conflict of interest policy when
she accepted a consulting gig with a key company
supplier, your policy will give you the factual
elements of what constitutes the misconduct.
From that you determine the information
you will need and how you will get it.
An investigation strategy is not engraved in
stone. The initial investigation strategy might
change as the investigation proceeds. Changing
the strategy as the investigation proceeds and
as additional information is learned is actually
a good thing. It shows you are testing your
assumptions and proofs against the facts as
you are learning them. When needed, you are
adjusting your approach. This ensures that your
investigation results will be supported by the
proof you assembled.
If the right steps are followed in assessing the
report and planning the investigation, you will
see that everything will go smoothly toward your
investigation’s conclusion. Skip a step, and you
will wind up frustrated and with a poor result. ✵
Meric Craig Bloch ( email@example.com) is Corporate Director,
Investigations for Shriners Hospitals for Children. He has conducted over 400
workplace investigations of fraud and serious workplace misconduct, and
is an author and a frequent public speaker on the workplace investigations
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