Reading time: approx. 7 minutes · For directors, HR, compliance, and managers

A report is not yet an established fact

A report may concern fraud, conflicts of interest, misconduct, abuse of authority, or other behavior perceived as improper or unsafe. The report is an important signal, but not yet a conclusion about what actually occurred. Nor is a formal fact-finding investigation automatically the appropriate first step. The organization must first understand what type of signal is at hand, which risks require immediate attention, and what handling is proportionate and due.

The primary task is not to immediately prove what happened, but to carefully determine what is required now.

The first 24 hours: establish calm and clarity

Responding swiftly is important, but prevent haste from leading to commitments, conclusions, or measures that are difficult to reverse later.

1. Assess safety and urgency — Determine whether there is an immediate threat of danger, harm, recurrence, or loss of information. Take only necessary interim measures and ensure they are not perceived as a premature judgment on those involved.

2. Carefully record the signal — Document what was actually reported, by whom, when, and via which channel. Keep facts, interpretations, and assumptions separate, and restrict access to the information strictly to individuals who need it for their role.

3. Clarify roles and communication — Determine who receives the report, who decides on next steps, and who maintains contact with the reporting person and other parties involved. Agree on what can be communicated, what cannot yet be shared, or what must remain confidential.

What type of signal is this, really?

Not every discomfort, conflict, or suspicion requires the same procedure. An initial classification helps determine the appropriate path without trivializing the signal or prematurely locking into a course of action.

• Potential integrity violation — fraud, corruption, conflict of interest, abuse of power, or breach of internal standards.

• Inappropriate conduct — for example harassment, discrimination, bullying, or sexual misconduct.

• Employment or workplace conflict — a strained working relationship, role ambiguity, or difference of perspective that does not primarily call for a fact-finding investigation.

• Complaint regarding policy or decision-making — an issue that potentially belongs in a standard grievance, objection, or HR process.

• Acute or potentially criminal conduct — a situation where immediate specialized or legal advice and potential contact with competent authorities may be necessary.

The chosen classification must not prejudge the outcome: first clarify carefully, then determine the appropriate path.

Choose the route that fits the issue

An organization may opt for an exploratory discussion, an informal intervention, handling by HR or management, a formal grievance procedure, mediation, a cultural or organizational review, or an independent fact-finding investigation. Sometimes multiple routes run in parallel; other times one must be concluded first.

Three questions before initiating an investigation

• Is there a clear and neutral investigative question?

• Are the relevant facts reasonably investigable?

• Is an investigation proportionate, capable of being carried out independently, and genuinely necessary to reach a decision?

Initiating an investigation simply to visibly 'do something' is insufficient. An investigation has a profound impact on all involved and must have a clear objective.

Ensure clear and independent governance

When an investigation is warranted, diligence begins with a clear mandate. Formulate at least who the commissioning client is, the scope and normative framework, which questions will be investigated, how independence is safeguarded, and how the right to be heard (adversarial process) is conducted. Also make agreements regarding information security, privacy, reporting, decision-making, and communication.

Select investigators based on expertise, independence, and suitability for the specific issue. For larger or more specialized investigations, a multidisciplinary team may be required.

Protect the position of all parties involved

Due care applies to the reporting person, the person under scrutiny, witnesses, and the wider organization. Prevent retaliation and speculation, protect confidentiality without promising absolute secrecy, and keep those involved periodically informed where possible. A report can have a major impact, even if a suspicion is ultimately unsubstantiated.

Confidential is not the same as secret

Share information only with individuals who need it for their role, but do not promise that information can remain with one person under all circumstances. Be transparent from the outset about the process, roles, and boundaries.

A report is not the end

Following the establishment of facts comes the managerial and organizational deliberation. What conclusions can be drawn, what measures are appropriate, and what do teams or individuals need for restoration? Moreover, look beyond the incident itself. Unclear responsibilities, weak internal controls, leadership conduct, or recurring patterns may warrant strengthening policy, leadership, and workplace culture.

Communicate carefully regarding conclusion, organize aftercare, and document how recommendations will be followed up. In doing so, a report is not merely concluded, but leveraged to make the organization safer and more reliable.

In summary

• Take every signal seriously, without immediately treating it as an established fact.

• First assess safety, urgency, and the risk of information loss.

• Keep facts, interpretations, and assumptions strictly separate.

• Determine which route is proportionate and appropriate.

• Ensure independence, clear roles, and diligent communication.

• Do not forget restoration, learning, and structural follow-up following conclusion.

This article provides general practical guidance. The appropriate approach always depends on the specific facts, internal regulations, and the legal context of the organization.

Issue: There is a report or suspicion →
Service: Integrity investigation →