Experts Discuss the Crucial First 48 Hours of an Internal Investigation and Beyond

When a company uncovers an anti-corruption problem, it must be ready to react quickly.  “The first 48 hours of any investigation are often critical to the success of that investigation,” Andrew Foose, Vice President of Advisory Services at NAVEX Global, said during a panel at the recent Global Ethics Summit, hosted by Ethisphere Institute and Thomson Reuters.  Foose and the other panelists, William Jacobson, a partner at Orrick, Herrington & Sutcliffe; Adam Briggs, Regulatory Compliance & Ethics Attorney for United Parcel Service; and Benjamin Gruenstein, a partner at Cravath, Swaine & Moore, detailed strategies for those crucial first days and also discussed long-term best practices for conducting effective investigations.  See also “How to Conduct an Anti-Corruption Investigation: Ten Factors to Consider at the Outset (Part One of Two)” (Dec. 18, 2013); “Developing and Implementing the Investigation Plan (Part Two of Two)” (Jan. 8, 2014).

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