Repeat Investigation Case Study
Over a period of time, the investigation team identified that the types of investigations specific to a particular type had increased and that during the investigation, when questioned, the awareness of what disclosures should be made by these staff members highlighted absence in knowledge, albeit that the individuals were senior management. It was felt by the investigation team that whilst there were procedures and an annual on line training event, the message was not getting out and on the basis, senior management was involved in these cases, the message was not being delivered further down the line to subordinates, exposing the risk of further cases.
What we did
On the basis that it was factually correct to inform the business that the controls were not working given the investigation team findings, it was important to deliver a message to the business that they needed to put a plan in place to ensure these issues did not arise in the future. As such a decision was made to raise this matter as an audit issue with an unsatisfactory rating.
The business owners of the policy relating to the repeat issue agreed that an action plan should be put in place, but equally given that any actions should come from adherence to the overarching code of conduct, then senior management should own and sponsor the action plan. An agreement was reached that the business owner would deliver a workshop to all senior management within the Group who in turn would sign up and deliver workshops to all their staff and inform the implications for staff not adhering to the specific policy.
The approach of raising this matter as an audit issue highlighted the problem through the board audit committee which in turn provided endorsed that an action plan needed to be put in place and repeat issues were minimised. The investigation team did not receive any such referrals post this exercise being enforced. Policies were revised and reissued and procedures reviewed to assess how disclosures could be captured.