Background

Organizations of all types and sizes may have occasions where they want to set up an internal investigation. This may be necessitated by matters coming to their attention that require immediate response. Organizations’ internal misconduct, irregularity, compliance breach and so on could all be such matters. An internal investigation properly carried out may help organizations stave off the brunt of resultant calamitous effect, thus gaining the upper-hand in handling the situation. With the foresight gained through an investigation, the organization can then come up with timely remedial measures to resolve these breaches.

This standard lays out the essential aspects of an internal investigation with a view for practical application. It was drafted in generic terms so that it may be tailored to meet different organizations’ needs. And it aims to help organizational users set up a well-rounded investigative process ready to be deployed when breaches happen. Organizational users are therefore advised to follow through its requirements for it to be effective.

Scope

ISO 37008 Internal Investigations of Organizations — Guidance provides guidance on the full cycle of an internal investigation for organizations, covering the establishment of the investigative policies and procedures, implementation of the investigation, the reporting of the investigation result and the performance of remedial measures.

Structure

This standard lays out five fundamental principles for its effective application (independent; confidential; competent and professional; objective and impartial; legal and lawful). Organizational users are advised to apply them throughout the process of an internal investigation because they can make the process more robust and stand up to scrutiny.

The document placed emphasis on the management support needed for an effective investigation. The senior management not only should make sufficient resources available but also should demonstrate its commitment by complying to the aforesaid principles.

This standard covers the pre-investigation stage, the actual conduct of the investigation and post-investigation stage. The pre-investigation stage deals with preparatory matters for an effective investigation. The actual investigative stage includes best practices that investigators can deploy. The post-investigation stage covers the essential efforts to remedy the relevant breaches giving rise to the investigation.

Main contents

Five principles that course through an investigation: ((independent; confidential; competent and professional; objective and impartial; legal and lawful) are five principles that should be applied throughout the investigation. At each stage of an investigative process, investigators need to reflect on these principles when making a material move.

Pre-investigation stage: sound preparatory efforts are central to a successful investigation conclusion. Preparatory efforts include making an investigation plan that outlines the composition of the investigative team and the scope of the investigation. Emphasis is given to efforts for preserving evidence, protecting witness and preventing interference.

The actual conduct of the investigation: document management and personnel interview are the two main building blocks of an investigative process. Document management is largely about identification of essential documents and scientific information analysis. Personnel interview also aims to produce useful information for analytical purposes. Both of them will contribute to the final investigative report.

Post-investigation stage: the final investigative report serves as the basis for post-investigative efforts. Such efforts mainly refer to possible remedial measures for the breaches giving rise to the investigation. Possible remedial measures may take the form of overhaul or adjustment to the organization’s existing compliance structure. Critical decisions by the organization’s top management should be taken at this stage including whether to self-report the breaches to the relevant authorities; whether and how to interact with external stakeholders; what remedial measures to take to address the situation.

WG8 Leadership

The project is led by Mr. Litong (Henry) Chen and Ms. Lifeng (Sally) Wen (China)

The Secretariat is held by China. Please email the WG Secretary, Min Cai, min.cai@bdo.com.cn with any queries.