Compliance Perspectives

Al Gagne on Responding to an Initial Incident Report [Podcast]


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By Adam Turteltaub

Internal investigations are always a hot topic, and this year they were the subject of a two-day, dedicated SCCE conference.  Al Gagne, the former Director of Ethics and Compliance of Textron Systems Corporation formed half of the pair of presenters that led the program.
In this podcast, Al shares his insights into how to handle the initial report of potential wrongdoing.   Handle it well, and the investigation begins on the right foot.  Handle it poorly, and the risks of missing something are significant.
Listen to Al as he shares advice on:

* How to handle the initial report in general
* Obtaining in the reporter’s own words and as descriptively as possible their concern about the alleged misconduct they report
* The importance of finding out whether the reporter was a witness or heard about the alleged incident second hand
* Assessing the credibility of the report
* The importance of knowing how recently the action occurred
* Determining if there were there other witnesses
* The desirability of having the reporter give his or her name
* What you should and shouldn’t promise the person making the report
* Understanding what the reporter wants, which is typically to have the misconduct stop
* How to discuss possible retaliation
* Keeping the reporter in the loop, and the advantage of being able to ask more questions of the reporter later
* The importance of advising the reporter not to share that they reported the incident with others
* Keeping control of the investigation
* The value of bringing in other internal experts and teams (internal audit and HR) judiciously
* Letting management know that an investigation is pending
* The risk of over-communicating the extent of an investigation
* Avoiding unnecessary harm

...more
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