Compliance InvestigationsAlthough most corporations have formal Compliance programs, all business entities have written or implied rules of conduct for employees, vendors, and contractors. When a breach of these rules of conduct occurs, it often results in measurable losses to the business and can often create a culture of non-compliance with business ethics that can create even more losses. In the case of companies potentially impacted by the Federal Sentencing Guidelines, this can result in hefty fines in addition to the financial losses caused by actual violations of the code of conduct. Generally, employee malfeasance is the culprit when an employee (or contractor) violates rules of conduct for one or more of the following:
Compliance investigations generally start with an allegation of wrongdoing, typically as the result of measurable inventory losses, a Compliance Hotline tip, or a confidential source. It is generally best to call upon the services of Frizell Group before an internal investigation might minimize the opportunity to resolve the issues in the most value-added manner possible. Frizell Group will consult confidentially with the client to discuss the allegation and the appropriate course of investigative action. Normally, appropriate documents are reviewed and trusted witnesses are interviewed before subject interviews of the employees accused or suspected of wrongdoing are conducted. Subject interviews are scientifically designed to elicit confessions from guilty parties and to help establish the innocence of those who have been wrongfully accused. Frizell Group has an excellent record of accomplishment in the conduct of subject interviews because all such interviews are conducted by experienced interviewers who have had specialized training. In addition, all interviews are personally reviewed by David P. Frizell, Jr., CFE, Frizell Group’s President (a former CIA polygraph examiner), or Thomas C. Kiefer, Managing Director (a former command-level law enforcement professional). Unlike a similar interview that might be conducted by the police for criminal violations, the use of a Frizell Group investigator for such an interview will allow more focus on business-related issues. This will help provide a determination of the nature and scope of each violation, the methodologies used, and the identities of others involved, so that the client will ultimately have the opportunity to seek criminal, civil and/or administrative remedies as a result of the completed investigation, and most importantly, will allow the client to implement the appropriate safeguards. |
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