Internal Investigations

Internal investigations according to international standards.

When there is a suspicion of serious misconduct or criminal offences within a company, a mere “clarification of the facts” is no longer enough. What is needed is a structured internal investigation – legally robust, traceable and reliable.

I conduct and support internal investigations, among other things on the basis of the United Nations Investigation Manual and comparable international standards.

Internal Investigations – United Nations Investigation Manual

Typical reasons for internal investigations

Internal investigations are usually required when internal or external indications of serious breaches of duty or criminal offences arise:

  • Suspicion of corruption or bribery
    Indications of improper payments, invitations or benefits in connection with contracts.
  • Fraud, embezzlement, asset transfers
    Irregularities in accounting, unclear cash flows, “side structures”.
  • Reports from whistleblower systems
    Anonymous or open reports from employees, suppliers or customers.
  • Compliance violations with criminal-law relevance
    Cartel arrangements, export control violations, sanctions breaches, data protection incidents.
  • Suspicion of organised structures
    Indications of coordinated conduct by several individuals, for example in purchasing, sales or logistics.
  • Sensitive business areas
    Areas with an increased risk of corruption or security issues, such as aviation or other security-relevant sectors.

Approach in internal investigations

Internal investigations must be legally sound, documented in a traceable way and at the same time sensitive in their handling of the people involved. In doing so, I follow international standards – including the United Nations Investigation Manual.

  • Clarifying mandate & structure
    Clarification of objectives, scope, reporting lines and confidentiality (Legal, Compliance, HR, supervisory bodies).
  • Investigation plan & document review
    A structured plan, identification and preservation of relevant documents and data.
  • Interviews & hearings
    Preparation, conduct and documentation of interviews with whistleblowers, witnesses and respondents.
  • Assessment & legal classification
    Allocation to possible criminal offences and assessment of labour-law and regulatory consequences.
  • Reporting
    Structured reports for management, supervisory bodies, authorities or contractual partners.
  • Interface to criminal proceedings
    Coordination with law enforcement authorities, decisions on self-reporting or disclosures, and support in parallel proceedings.

Sectors and contexts

Internal investigations arise in a wide variety of industries – but they are particularly sensitive in regulated sectors and companies with an international footprint.

Business & corporate groups

Investigations in companies, corporate structures or joint ventures – from the assessment of a report through to reporting to the management board or supervisory board.

Aviation & aircraft manufacturers

Internal investigations in airlines, airports, aviation organisations or aircraft manufacturers – for example in cases of suspected corruption in procurement, cargo crime or allegations of espionage.

International context

Investigations involving several jurisdictions, different cultures and varied regulatory requirements – reporting and communication in German or English.

Discreet initial consultation

If you are considering a possible internal investigation or already have indications of serious misconduct, a structured first step is crucial.

I am available for a confidential, structured initial consultation – if desired together with internal or external colleagues (Legal, Compliance, HR).

Contact:
E-mail: martin@heynert.com
Phone: Office +49.391.5982-243, Mobile +49.171.4135269