Audit Committee Responsibilities Before, During and After an Anti-Corruption Investigation: Determining When and How to Proceed (Part Two of Four)

Involving the audit committee in appropriate internal investigations helps ensure that the investigation is conducted properly and the company and its employees achieve the best resolution possible.  Determining the audit committee’s optimal role can be difficult, however – a company must decide what issues warrant the audit committee’s attention and then determine the audit committee’s proper place in the actual investigation.  The Anti-Corruption Report is examining the audit committee’s responsibilities in anti-corruption investigations in a four-part article series.  This, the second article in the series, discusses vetting complaints for the audit committee, determining when an investigation is needed and who should lead that investigation.  The first article in the series, “Five Steps to Take Before the Investigation Begins,” detailed the responsibilities of the audit committee, the risks and liabilities the audit committee faces and steps the audit committee should take before the need to investigate arises.  The third article will discuss best practices at the outset of the investigation, the wisdom and timing of retaining outside counsel, the information-gathering process and the need to document the investigation.  The fourth article will discuss the audit committee’s responsibilities concerning self-reporting, remediation and SEC disclosures.  See also “A Guide to Disclosing Corruption Investigations in SEC Filings (Part Three of Four)” (May 29, 2013).

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