Multinational companies should have in place well considered protocols for investigating claims of alleged internal wrongdoing. Claims of misconduct are often multi-faceted. For example, a claim of unlawful retaliation may also require a review of whether the employee has a reasonable basis for believing that the employer is engaging in wrongful or perhaps illegal conduct. This may, in turn, require an investigation into whether the alleged wrongdoing that is the subject of the complaint actually occurred.
Investigation protocols therefore should provide guidelines that assign investigation roles and responsibilities among various key stakeholders, which may include the general counsel, the chief compliance officer, chief risk officer, head of human resources, and others.
