Conducting C-Suite Investigations


EthicsPoint presented a webinar on conducting C-Suite Investigations, with Sally Rhys, BA, MS, CCEP of Business Ethics FocusNo-one wants to believe that allegations against the C-suite (Senior Executives) could be true. But with daily news reports of more cases of illegal and unethical transgressions by senior leaders, we all know that every organization is potentially at risk. It can happen at any time, even in your own organization. Are you prepared to handle such a crisis? These are my notes from the presentation.


Sally Rhys started off with a fraud scenario involving the CFO: A call from someone that she thinks the CFO is overstating earnings and has convincing reports.” What do you do now?

Investigating C-suite involves bigger risks. There are also psychological barriers involving loyalty to the organization and its management. Sally points out the need for a plan:

  1. Secure a sponsor.
  2. Engage a a stakeholder team to act as a sounding board.
  3. Identify the positions which require an investigation protocol.
  4. Create plans for each position that needs a protocol. You may want to have an outside investigator for some positions. You may also want to have a PR plan and methods for dealing with clients, employees and other stakeholders. You also want to well document the steps and the investigation. You also want to be clear about the non-retaliation policy.
  5. Seek board approval. Craft a persuasive message to convince the board to approve a C-suite protocol.
  6. Publish the protocol. Write it down, publish it in the code and make it accessible. Only do this if you are actually going to follow the protocol.

It is good to have some method for quickly determining if there is some basis for the claim. You need to show that take the allegation seriously, but you want to move quickly to respond appropriately.

It is important to show the board where executives go wrong.

The attendees said the most likely chilling effect on a C-Suite investigation is the concern that you will not be supported.  Of the attendees, 46% picked this choice out of the four.

It is important to protect yourself. Make sure you have support of the board or other key stakeholders. Be professional and leave emotions at the door. be respectful and thorough. You need to stay credible.

Sally thought it was important to separate the role of general counsel and the compliance officer/investigator. Of course, you need to have a protocol for yourself/your position.

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