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WhitePaperMaturityModel V2
WhitePaperMaturityModel V2
WhitePaperMaturityModel V2
How Mature is
Your Workplace
Investigations
Program?
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Table of Contents
Footnotes 14
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.
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.
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
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.
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.
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.
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
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