Donna Boehme – Compliance & Ethics Professional – June 2014
The other day I ran across a column from a compliance “expert” with an impressive legal background, including a stint at DOJ. The topic: Important things to remember in an internal compliance investigation. Hot cup of java in hand, I settled in for a good read on what a fellow compliance practitioner regarded as “must do” in an internal probe. Here is my disappointed face. :- l
Instead of a pithy reminder on confidentiality and non-retaliation, two (out of seven) pillars of a good internal investigation guideline aimed at ensuring the integrity of the compliance program, the author had expounded on attorney-client privilege, attorney work product, voluntary disclosure, and other items cribbed directly from the in-house lawyer’s playbook. Certainly all those items should be managed correctly in close coordination with Legal. But, meh. What a missed opportunity!
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