How to plan and conduct an internal investigation


Produced in partnership with Noel Power of Addleshaw Goddard
Practice notes

How to plan and conduct an internal investigation


Produced in partnership with Noel Power of Addleshaw Goddard

Practice notes
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An internal investigation is a legal process undertaken by an organisation (with or without outside counsel) to review and identify facts relating to a specific allegation, concern or misconduct and remediate potential irregularities.

What sort of events may trigger an investigation?

Common scenarios that may trigger an investigation include:

  1. •

    an individual raising a concern internally via a whistleblowing hotline or otherwise (whistleblower)

  2. •

    a response to a regulatory or criminal agency demand

  3. •

    part of due diligence in advance of a merger or acquisition

  4. •

    a civil litigation claim

  5. •

    an internal or external auditor’s report

  6. •

    media reports

  7. •

    an external allegation, eg from a customer or counter-party

Why conduct an internal investigation?

Internal investigations are an important process in establishing the factual circumstances of a particular event or series of events in a way which best protects the organisation and the board. The overriding aim should be to determine the facts and mitigate any legal, regulatory and reputational outcomes, ie:

  1. •

    establish the relevant facts to enable the board

Noel Power
Noel Power

Managing Associate, Addleshaw Goddard

Noel Power specialises in internal and regulatory investigations and white-collar criminal defence. Noel advises large corporate clients, financial institutions and senior executives across a range of industries including financial services, transport, pharmaceuticals and defence, on their interactions with the UK Serious Fraud Office, the National Crime Agency, HM Revenue & Customs and the US Department of Justice.

Noel focuses his practice on complex, multi-agency and cross-border investigations particularly involving bribery, fraud, corruption and money laundering. Noel’s practical experience of investigating and defending organisations and individuals has led to a compliance and advisory practice assisting national and international organisations in designing, implementing and testing effective compliance measures.

Noel has been listed as a key lawyer by the Legal 500 2022.

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Jurisdiction(s):
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Key definition:
counsel definition
What does counsel mean?

a barrister;

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