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How Mature is
Your Workplace
Investigations
Program?

Copyright © 2023 Case IQ. All rights reserved. Case IQ and the Case IQ logo are registered trademarks of Case IQ. 04.23
Table of Contents

Why a Maturity Model? 2

What is a Maturity Model? 3

What is Workplace Investigations Program Maturity? 4

The Five Stages of Program Maturity 5

What Does an Optimized Program Look Like? 7

The Importance of Data Maturity 11

The Benefits of Using a Maturity Model 12

About the Author 13

Footnotes 14

Better Case Management Software, Better Investigations 15

Copyright © 2023 Case IQ. All rights reserved. Case IQ and the Case IQ logo are registered trademarks of Case IQ. 04.23
Why a Maturity Model?
Ask a compliance officer2 if they believe This perspective perpetuates the status quo, A Program assessment should be done on
their organization has a good workplace whatever that looks like. The perspective both a micro and macro level. The micro level
investigations program. Most will say yes. 
 gives no thought to what the organization’s considers how well individual investigations
But what they may mean isD workplace investigations program (the are being conducted. The macro level looks at
+ We think we are doing it right “Program”) could be. There is no assessment the Program more generally.
of the Program, its strategic goals, and its
+ A terminated employee has not sued the
potential contribution to the organization.

organization after an investigation


Or is it the unknown unknowns? Program
+ Okay, a terminated employee has sued
the organization, but we settled the claim managers may not know what good looks like,
Organizations should use a
and that opportunities exist to improve the
+ Our lawyers are not complaining about maturity model to evaluate their
Program.

our investigations Program and its future. This


A workplace investigation does more than whitepaper will explain how.
+ Our managers are not complaining about
determine if employee misconduct occurred.
our investigations
An investigation should promote business
+ Our HR colleagues are not complaining success. It should support the other parts of
about our investigations the compliance program and bolster a speak-
+ Our CEO says wonderful things about our up culture. It should identify unacceptable
compliance program business risks. It should show where financial
control weaknesses exist. It should identify
+ We do not get many hotline Reports.
accountability lapses.
+ Okay, we get many hotline Reports, but
they are mostly from disgruntled
employees.

Case IQ Whitepaper | How Mature is Your Workplace Investigations Program? 2


What is a Maturity Model?
Performance evaluation tools help improve a Using a maturity model to evaluate your Maturity reflects a function’s expected
business function’s efficiency, identify Program will give you the ability to: performance. The more significant the
improvement areas, and develop policies and maturity, the more you can turn events or
procedures to help teams grow. A maturity Benchmark performance. This helps mistakes into teachable moments that lead to
you determine where your Program is in
model is one of these tools.
improvements.

its current state. You can then set clear


The model judges how well an organization objectives and allocate resources to Using a maturity model will not fix deficiencies,
improve performance.
improves an internal function from a given however. A model only helps to identify areas
state. It assesses a function’s maturity level in where the program is not operating according
its quality or resources. It helps determine a Energize performance to leading practices and allows you to
improvement. This helps you create
function’s long-term trajectory and determine strategies to improve operations
action plans to resolve performance
performance. deficiencies and improve maturity. and processes.

Create a common nomenclature.


Defining goals, key objectives, and
values with a common language can
translate into consistent, repeatable,
and predictable performance.

Case IQ Whitepaper | How Mature is Your Workplace Investigations Program? 3


What is Workplace Investigations Program Maturity?
Program maturity is a measure of how well- The processes in the Program are mature The Program is mature – on the macro level
defined and controlled your investigation when they have each of these qualities: – when it has these characteristics:
processes are. An elevated level of maturity
shows that your investigators document Defined. Procedural steps are clearly specified. Standardized. Investigations are managed
There is consistency in results. consistently among teams, divisions,
processes well, they understand and follow
geographies, and professional disciples (e.g.,
standard procedures, and there is continued Human Resources, Internal Audit, Legal and
investigation process improvement.
Corporate Security). Data is shared for cross-
Efficient. The process is not cumbersome and
functional impacts.
requires reasonable efforts. Process delays are
When investigation processes are well an exception.
designed, encourage collaboration between
Measured. Program managers use data to
investigators and stakeholders,4 and reinforce
track process maturity using consistent metrics,
accountability, the Program has higher Documented. The decision points regarding
such as key performance indicators.
Report intake, the Preliminary Assessment,5 

process maturity. This leads to better and fact-gathering are detailed. Investigators,
investigation results and greater contributions Program managers and stakeholders know
where to find the information. Analyzed. Program managers evaluate
to business success. investigation processes for efficiency and
effectiveness.
Automated. The process automates any
suitable case-management steps.

Effective. The process produces the


anticipated results consistently.

Case IQ Whitepaper | How Mature is Your Workplace Investigations Program? 4


The Five Stages of Program Maturity
Program maturity models can be descriptive,
meaning they help you assess your current 1. Initial. This is the first level and the
beginner stage. 2. Managed. This is the second level and
the proficient stage.
processes. They can be prescriptive, meaning
they define optimal process maturity and Your Program is thoroughly ad hoc. You react There are some standard processes. There is
provide guidance on achieving it. Finally, they to situations rather than predict them. There is some management foundation. Investigative
can be comparative, meaning they help you minimal focus on process. The approach to knowledge rests with one or just a few people.
understand how your processes compare to resolving the Report, and the chances of a Individual investigators may document their
those in other organizations.
successful resolution, is entirely dependent work properly, but it is not widespread.
Think of each maturity stage as a step. At on those colleagues who manage it and what Investigators work in silos with minimal
each stage, the Program needs to achieve goals they decide. There are either no collaboration.

certain goals to advance. Each maturity stage documented procedures, or the procedures An example of this stage is a headquarters-
is another step from ad hoc processes to are generic and probably ignored.
managed Program that purports to specify
optimized ones. A one-person compliance team where Report processes and standards, and investigations
investigations are simply referred to Human are managed by regional teams or other
Here are five stages in maturity for a
Resources with no coordination or departments. The Program manager in the
workplace investigations program:6
collaboration is an example of this stage. home office is a proficient investigator, but the
These investigations have no impact on rest of the team is not. Each region,
business operations. Technology tools are not department or investigator acts
used other than perhaps a hotline reporting independently of others. There is no
channel. incremental learning, teachable moments, or
collaboration.

Case IQ Whitepaper | How Mature is Your Workplace Investigations Program? 5


These investigations have minimal impact on These investigations have some impact on There is an effort to control variations in
business operations, and any “lessons business operations. Investigators try to investigator techniques. The Program
learned” are anecdotal. Technology tools are identify root causes and lessons learned. compares its processes and operations to
used to warehouse investigation files. If data is Technology tools are used to warehouse those at other organizations.

collected, a lack of technique consistency investigation files, and there is some attempt All Reports are retained in the case-
prevents meaningful analysis.
 to ascertain trends from the data.
 management tool even if some are resolved
without an investigation. The investigation
plans now include stakeholder business

3. Standardized. This is the third level


and the savvy stage. 4. Predictable. This is the fourth level and
the expert stage.
goals. Periodic analyses are prepared. The
analyses use common industry benchmarks.


Investigators know the standardized and The investigative process infrastructure and
documented processes. Knowledge of resources are used to achieve reliable results.
investigative techniques and procedures
does not center on a specific person or small
Program managers assess and analyze the
investigative processes. They may also
5. Optimized. This is the highest level and
the mastery stage.

group. There is cross-functional and cross- benchmark the program against industry The Program is continuously improving and
team collaboration. The Program is working leaders.
focused on innovation. Processes follow
towards consistency and uniform delivery.
An example of this stage is a headquarters- current leading practices. Process variations
An example of this stage is a headquarters- managed Program that provides direction and exist for some cases and regions, but they are
managed Program that provides direction and training to investigators. The investigations controlled. Results are dependable.
training to investigators. People know the are monitored by a Program manager. There Regulatory and marketplace expectations are
processes and try to follow them. are frequent case check-ins to ensure that the incorporated in the processes. Program
Investigators have some level of competence. techniques are followed. Guidance is managers provide thought leadership in their
Investigators collaborate with each other, as provided to assist with any challenges or field. Case-management tools are integrated
needed. Information is shared across teams. investigator concerns. into Program operations. Analytics are used
by other stakeholders to plan their own
initiatives.
Case IQ Whitepaper | How Mature is Your Workplace Investigations Program? 6
What Does an Optimized Program Look Like?
An optimized Program begins with the 3 An investigation is a tool to learn the true 3 Program managers think beyond 

proper mindset. Program managers facts to facilitate manager decision the organization. What are other
consider these strategic factors: making. An investigation should identify organizations doing? What industry
contributing factors and unacceptable benchmarks might help us? Is our
3 The process cannot just react to Reports
business risks. The Program must Program following current leading
and similar concerns. The process must
contribute to the organization’s successg practices?
look proactively to identify vulnerabilities
that may enable future employee 3 The Reporter7 and Subject8 are not the
misconduct. For example, an increase in only stakeholders in an investigation. The
Reports of inappropriate conduct at process must consider the needs and
organization-sponsored events in some perspectives of management, auditors, An optimized Program considers
locations can be analyzed to identify regulators, and stockholdersg the regulatory framework in which
weaknesses in business controls. The the organization operates. The
3 The Program is not just an aggregation of
corrective steps can be applied to other framework could be a mandatory
Report-processors. The Program is a key
locations as well to reduce the risk that one, such as the Joint
part of the compliance program, Human
similar problems may occur elsewhere. Commission’s standards for
Resources process, and the Legal
healthcare providers or Securities
function.

Exchange Commission
regulations for brokerage firms.

Case IQ Whitepaper | How Mature is Your Workplace Investigations Program? 7


The regulatory framework could also be advisory, such as the US Department of Justice’s standards for the Evaluation of Corporate
Compliance Programs.9 An optimized Program meets these DOJ expectations:

The process is designed to consider Investigators are competent10 
 Program managers constantly
the organization’s size, geographical and deployed based on case need update procedures to reflect added
footprint, and Report history. and management considerations. 
 information learned.
The investigators have the requisite
authority and leadership support.
The hotline and other reporting Investigators are given necessary
channels are designed to minimize training, certifications, and experience
risks of retaliation, allow anonymous Data gathering is constantly for their roles and responsibilities.
reports, and have appropriate improving so policies, procedures, and When needed, further training and
processes for evaluating reports. controls can be updated as needed. development is provided.

Investigations are properly scoped, Insights are gathered from Consistent investigation results
and appropriately conducted. investigations to help managers enable managers to apply discipline
incorporate lessons learned into their consistently. This promotes
operations and risk assessments. organizational justice and procedural
fairness.

Case IQ Whitepaper | How Mature is Your Workplace Investigations Program? 8


An optimized Program is properly structured with internal standards for resolving Reports and conducting workplace investigations. 

The process architecture includes at least these documents:

A Board of Directors resolution 
 A serious Report escalation protocol Investigations data analytics 

that delegates compliance-related to ensure that key management leaders to report on investigation activities,
investigative authority. are informed of Reports of a sensitive, Reports received, and trends and
material, or significant issue once the observations. The analytics are
Report is received. provided to stakeholders monthly,
quarterly, and annually.
An internal investigations policy that
specifies the standards for the hotline,
authorizes the investigation function, Operating standards to specify the
and specifies prohibitions on retaliation, steps by which Reports are initially Template hotline responses · to
an employee’s duty to cooperate, and evaluated and triaged to determine the ensure consistency in managing
the expectations for confidentiality, appropriate resolution criteria. Reporters and others.
among others.

A protocol that specifies the Investigation document templates


A compliance committee charter to standard techniques an investigator to ensure efficiency, consistency, and
establish a committee of stakeholders is expected to follow and how to use effectiveness.
to share information and analytics. the Program’s technology tools.

Guides and practice bulletins to offer


A consistent discipline policy 
 An integration plan with other continual guidance to investigators.
to ensure that disciplinary decisions 
 departments, such as Human
are made as the result of a proper Resources, to allocate Reports for
investigation with appropriate appropriate handling.
consideration of relevant factors.

Case IQ Whitepaper | How Mature is Your Workplace Investigations Program? 9


These documents evolve, change, or become
obsolete based on changing needs,
investigation experiences, and as new
information is learned.
An optimized Program protects
An optimized Program records all Reports its resources. An investigation can
and related activities in the case- be conducted if the allegation
management database. Depending upon the involves misconduct. If the Report
nature of the Report, investigations are relates to other areas, the Report
sometimes necessary and appropriate.
is referred to a more-appropriate
However, investigations are not a tool to department for further handling.
devolve responsibility for managing incidents
of inappropriate behavior, and they should be
used to address minor matters that could be
resolved by managerial action of a less formal
nature. When used to resolve lesser disputes
or minor incidents, investigations can
unnecessarily delay the resolution of a matter,
restrict managerial initiative, and limit the
opportunity for open dialogue and apologies
between disputing parties.

Case IQ Whitepaper | How Mature is Your Workplace Investigations Program? 10


The Importance of Data Maturity
The Program needs data on individual cases There are five levels to measure your
Data-driven. Compliance professionals,
as well as the Program more generally. This Program’s data maturity: investigators, and colleagues in other
data informs the Program managers of Report departments work together cohesively. Data
sources are integrated. Processes are improved
trends, case-clearance rates, and other data Data-aware. Information is compiled manually based on the data. Costs are reduced, and the
from various systems. Data gathering is ad hoc,
points. Program managers can then turn data program can be scaled as needed.
and the results are often distrusted by
into insights for management. The data can stakeholders.
also be measured against industry
Data-predictive. Data is being used to
benchmarks.
anticipate resource needs, risk areas, and
Data-proficient. Key performance indicators business vulnerabilities. Problems identified in
You need the right technology for case and other metrics are tracked. Limitations to one geography or division can be anticipated in
data gathering are understood, such as too
management and analytics. If it is too other places and mitigated.
many sources, incomplete investigation data,
technical, cumbersome, or slow that your and poor investigation techniques that hurt the
investigators cannot use it efficiently, it may data’s reliability. The more mature your process and tools for
offer little value. It is also important to have gathering and analyzing investigation data,
technology that integrates well with your Data-savvy. Investigation data is used to make
the better you can respond to areas of
processes. The technology should be important decisions. Improved data quality unacceptable business risks. This is the key to
improves cross-department partnerships and
sufficiently user friendly so that other showing your value to your stakeholders,
breaks down data silos.
departments can use it with minimal friction. especially your business leaders.

Case IQ Whitepaper | How Mature is Your Workplace Investigations Program? 11


The Benefits of Using a Maturity Model
Having process maturity means your Program Another benefit to using a maturity model is
can respond to new risks and opportunities. the ability to improve your Program’s
This agility is key to your effectiveness. The capability. By identifying current levels,
right technology tools can facilitate quick deficiencies and strengths, Program A maturity model will allow you to
improvements.
managers can recognize the areas they need align your investigators toward
The organization gets some benefit from your to improve.
strategic objectives. You can build
Program even at lower maturity stages. The As your Program becomes mature, the a Program that fits your
organization’s risk profile, investigation history, processes work as intended. You can reliably organization’s unique needs and
and the resources it can devote to the meet stakeholder needs. You can protect the priorities. This may create a
Program each impact its maturity level. speak-up culture. Your investigation findings workplace that runs more
Program manager should be encouraged to are more dependable and credible.
smoothly and effectively.


“right size” the Program for their organization.


Program managers can then set realistic
A benefit of using a maturity model to evaluate expectations. You can start with the basics,
Use a maturity model. Discover
your Program is the model’s focus on build up, assess investigator performance,
your unknown unknowns.
continuous improvement and learning. If your and then move on to more complicated
Program is currently at the lower stages, you topics.

can identify the strategies you need to get A maturing Program helps with your internal
your Program functioning at higher levels. and external benchmarking efforts. Data
standardization enables you to make credible
observations regarding your Program

Case IQ Whitepaper | How Mature is Your Workplace Investigations Program? 12


About the Author
Meric Craig Bloch is the Principal of Winter Meric is an attorney, a Certified Compliance
Compliance LLC, a consulting practice and Ethics Professional – Fellow, a Certified
helping organizations create effective internal Fraud Examiner, a Professional Certified
investigations programs through investigation Investigator, and has written two books on
process design, investigator training, and investigations as well as chapters in industry
investigations management.
publications. He is on the faculty of the
He has designed, implemented, and managed Society of Corporate Compliance and Ethics’
the workplace investigations processes for Basic Compliance and Ethics Academy.

multinational Fortune 500 companies, trained
thousands of HR and compliance
professionals to conduct investigations, and
has conducted more than 400 internal
investigations of fraud and serious workplace
Meric Bloch is the Principal at
misconduct in the US and internationally.
Winter Investigations, an
investigations consulting firm.

Meric can be contacted at


meric@winterinvestigations.org.

Case IQ Whitepaper | How Mature is Your Workplace Investigations Program? 13


Footnotes
"@ Meric Bloch is the Principal at Winter Investigations, an investigations consulting firm. Meric can be contacted at
meric@winterinvestigations.org@
/@ For convenience, this whitepaper presumes that the incident-management and investigation processes are handled by
an organization’s Compliance Department@
@ A “Report” is an initial notification by an employee or someone else that there is an actual, suspected, or possible
misconduct. A Report is generally made by a colleague directly impacted@
9@ A stakeholder is someone who has an indirect interest in an investigation and may be affected by its actions and
outcomes@
@ The process for assessing a Report for the purposes of categorization, taking preliminary measures, prioritization, and
assignment for further handling. It is an initial review of assertions and evidence to determine the potential validity and
relevance of a Report and to determine what action, if any, is necessary@
@ This is an adaption of the Capability Maturity Model which was originally created to measure software 

development processes@
!@ The “Reporter” is the person who makes a Report@
@ The “Subject” is the employee against whom a Report is made@
@ While it is true that the risk of a DOJ criminal investigation may be slim or your may not be subject to US law, the DOJ
standards are considered the leading standards for compliance program design@
"@ “Competence” means the skills, experience, and training an investigator needs for types of cases to which they are
assigned. Competence is maintained with additional training and development.

Case IQ Whitepaper | How Mature is Your Workplace Investigations Program? 14


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