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Six Basic Steps for Investigating Allegations of …

Six Basic Steps for ItitiAllti fInvestigating Allegations ofFraud and MisconductABA Sifb& ElABA Section of Labor & Employment Law2008 Annual CLE ConferenceDenver, COJeff Heller, Assistant General CounselBP America Winfield Road4101 Winfield RoadWarrenville, IL 605556 Investigation Steps for Internal Investigations Concerning Fraud, Compliance Matters and g,pInternal RisksInitial Analysis and Role AllocationInitial Analysis Fact Finding InterviewingPlanning and LeadingInitial Analysis and Role AllocationFact Finding, Interviewing and ReinterviewingPlanning and Leading Investigation analysisTaking immediate Steps if The Investigation PlanThe Comm nication Plan Planning Ta k i n g immediate Steps if necessary Selecting an investigation team The Communication Plan Timetable Case File Leading & Advising Planning Arranging Opening Conducting/questioning ClosingFollowing UpReportingAnalysing the Evidence Who was interviewed?

Key Questions for Initial Analysis Upon Notification of a Compliance Breach, Fraud, SOX Issue, etc. Who is alleged to have acted wrongly?What is the alleged violation? Is an investigation necessary?investigation necessary?

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