Determining the scope of the investigation
Determining the scope of the investigation at the outset is crucial for a number of reasons, including controlling the costs of the investigation (including the costs of external advisers) and avoiding ‘mission creep'. However, any new issues uncovered during the course of the investigation must still be appropriately dealt with.
It is good practice for the investigation team to raise new issues or lines of enquiry that arise during the course of the investigation with the team leader but not to investigate these matters without separate authorisation.
The scope of the investigation should be carefully considered in each case and defined to be sufficiently wide to ensure that the conclusions will withstand any subsequent challenge by, for example, an external regulator.
Once the scope of the investigation has been set, appropriate corporate authorisation should be obtained from senior management (eg the Chief Operating Officer). The success of the investigation will depend to a large degree on the cooperation of those being investigated and the endorsement of senior management will be crucial in order to secure this cooperation.
Other considerations include:
- whether it is appropriate to engage external advisers
- the basis and nature of the relationships with all business partners identified by the investigation and gather relevant contracts and other information relevant to that relationship