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Whistleblower Incident: How to Prepare for an Internal Investigation

The most important steps to follow in order to successfully investigate whistleblowing cases in an efficient way

Sabine Stöhr Sabine Stöhr

    Your company has set up a whistleblower system. But how do you deal with incoming reports now? We have summarised the four most important steps in the internal investigation of a whistleblowing case.

    Internal Investigations – 4 Steps for Processing a Whistleblowing Case

    Step 1: Separate the Wheat from the Chaff

    First and foremost, you should identify reports that are not compliance-relevant or are even denunciatory. These types of reports do not require an investigation. Nevertheless, it is important to provide feedback to the whistleblower and, where appropriate, take action if an abusive report has been made that is clearly in breach of internal policies.

    The bulk of the investigation generally consists of the evaluation of documents, as well as interviews with employees and potential further discussions with the whistleblower.

    Step 2: Contact the Whistleblower

    Establish communication with the whistleblower as soon as possible. If the whistleblowing is not responded to within a few days, you risk employees losing confidence in your whistleblower system and its credibility being damaged. Ideally, develop a whistleblower feedback template in advance so that you can react to reports quickly. If a report doesn’t contain sufficient grounds to suspect actual misconduct, be sure to ask the whistleblower to provide more detailed information on the incident in question. Digital whistleblowing systems allow whistleblower communication by means of integrated mailbox functions.

    All relevant documents and investigation results should be saved in the secure Case Management area of your whistleblowing system.

    Step 3: Get to the Bottom of Things

    Internal investigations should be initiated promptly if there is sufficient evidence to indicate that a compliance violation has occurred. The bulk of the investigation generally consists of the evaluation of documents (including evidence received from the whistleblower), as well as interviews with employees and potential further discussions with the whistleblower. When doing this, make sure to comply with labor law, confidentiality and data protection requirements. Ideally, all relevant documents and investigation results should be saved in the secure Case Management area of your whistleblowing system.

    Step 4: Take Corrective Measures

    After the completion of any investigation, you will need to summarize results for management, including any corrective measures that have been taken or are planned. Sanctions and other processes should be transparently communicated within the organization. At the end of the investigation, close the incident in your Case Management system and anonymize any collected personal data, if necessary. For reporting and archiving purposes, all cases should remain within the whistleblower system.

    Digital whistleblowing systems allow whistleblower communication by means of integrated mailbox functions.

    To Sum Things Up:

    • Carefully consider how your organization plans to respond to an incoming report/incident if the report is received while you are still in the process of implementing a whistleblowing system.
    • Opt for a whistleblowing system which allows you to process cases in a well-structured way and to communicate securely with the whistleblower.
    • In the event that you receive a report, react quickly and follow the steps outlined above.

    Our digital whistleblowing system EQS Integrity Line supports you in the process management of your whistleblowing cases. 

    Sabine Stöhr
    Sabine Stöhr

    Senior Product Manager – EQS Group | As Senior Product Manager for EQS Integrity Line Sabine is an expert on the implementation of whistleblowing systems. She is based in our Zurich office.

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