Closing a whistleblowing report through investigation and compliance
A report that also came in through the client's supply-chain channel was handled through an internal investigation that met both parties' expectations and preserved confidentiality and the prohibition on retaliation, and it was closed with root-cause compliance remediations.
The report became a test of the client relationship
The German customer within the scope of the LkSG (German Supply Chain Due Diligence Act) wanted to see, as a process, how the report was handled; weak execution would have put the order relationship at risk.
The protection of the whistleblower and the rights of the reported employees were observed with the same diligence.
Our Approach
Keeping the commercial objective at the centre, we broke the legal risks down into measurable steps.
01 · Channel Discipline
The steps of recording, confidentiality and the prohibition of retaliation were carried out.
02 · Investigation
The allegations were verified/ruled out with a proportionate review plan.
03 · Root Cause
The findings were linked to policy, training and control corrections.
Timeline
The main stages of the process.
A closure that preserved client trust
The report was concluded through a documented process, presented as a process example during the client audit, and the compliance programme was strengthened with root-cause remediations.
- Protection of confidentiality and the prohibition of retaliation
- A documented investigation process
- A defensible file in the customer audit
- Linking the root cause to the compliance programme
Services Involved in This Matter
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Sectors
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Owing to the legal profession's duty of confidentiality and client privilege, the files are anonymised. In a meeting, within the limits of confidentiality, we can describe our comparable experience more concretely.
In a short preliminary meeting, we take in the objective, existing documents, parties, time pressure and critical risks. Then the scope, team, timeline and fee model are clarified.
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