Corporate Internal Investigations: Keys to an Effective Work Plan, Data and Document Management, and Budget
As described in the first White Paper in this series on internal investigations, "Conducting an Effective Internal Investigation—An Overview," corporations are under increased scrutiny by regulators across the globe, and as a result, it is more important than ever for companies to conduct an effective, defensible internal investigation when allegations of misconduct arise. An effective internal investigation allows companies to proactively examine the facts and assess any associated legal, financial, and reputational risks, whether or not a related government investigation or civil litigation is underway or anticipated.
But investigation costs can escalate quickly, especially with investigations that cover a significant period of time and/or territory, or that involve conduct that may potentially expose the entity or individuals to criminal penalties or significant civil liability. A work plan and budget are key to both ensuring a thorough investigation and managing investigation costs.
This White Paper summarizes considerations for creating an effective work plan for an internal investigation, successfully managing the collection and production of data and documents, and planning for the categories of expenses that typically arise in an internal investigation. We also offer guidance on how to budget for each line-item. Although each work plan and budget will necessarily vary in its components and costs, the categories described below should be considered when setting the work plan and budget in virtually every corporate internal investigation. We conclude by offering a "checklist" of issues and tasks to consider in preparing an effective work plan, managing data and documents, and formulating an investigation budget.
