Internal investigations of organizations — Guidance

This document gives guidance on internal investigations within organizations, including: — the principles; — support for investigations; — establishment of the policy, procedures, processes and standards for carrying out and reporting on an investigation; — the reporting of investigation results; — the application of remedial measures. This document is applicable to all organizations regardless of type, size, location, structure or purpose. NOTE See Annex A for guidance on the use of this document.

Enquêtes internes des organisations — Recommandations

General Information

Status
Published
Publication Date
27-Jul-2023
Current Stage
6060 - International Standard published
Start Date
28-Jul-2023
Due Date
02-Sep-2023
Completion Date
28-Jul-2023
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ISO/TS 37008:2023 - Internal investigations of organizations — Guidance Released:28. 07. 2023
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TECHNICAL ISO/TS
SPECIFICATION 37008
First edition
2023-07
Internal investigations of
organizations — Guidance
Enquêtes internes des organisations — Recommandations
Reference number
© ISO 2023
All rights reserved. Unless otherwise specified, or required in the context of its implementation, no part of this publication may
be reproduced or utilized otherwise in any form or by any means, electronic or mechanical, including photocopying, or posting on
the internet or an intranet, without prior written permission. Permission can be requested from either ISO at the address below
or ISO’s member body in the country of the requester.
ISO copyright office
CP 401 • Ch. de Blandonnet 8
CH-1214 Vernier, Geneva
Phone: +41 22 749 01 11
Email: copyright@iso.org
Website: www.iso.org
Published in Switzerland
ii
Contents Page
Foreword .v
Introduction . vi
1 Scope . 1
2 Normative references . 1
3 Terms and definitions . 1
4 Principles . 3
4.1 Independent . 3
4.2 Confidential . 3
4.3 Competent and professional . 3
4.4 Objective and impartial . 3
4.5 Legal and lawful . 3
5 Support for internal investigations . 3
5.1 Resources . 3
5.2 Leadership and commitment . 4
6 Establishment of investigation policy or procedure . 4
7 Safety and protection measures . 4
7.1 Preserving and securing evidence . 4
7.2 Protection of and support to personnel involved in investigations . 5
7.3 Anti-retaliation . 5
7.4 Safeguarding . 5
8 Investigative process.5
8.1 Investigation team . 5
8.1.1 Appointment of the investigation team . 5
8.1.2 Investigation reporting line . 5
8.2 Preliminary assessment . 6
8.3 Determining the scope of the investigation . 6
8.3.1 Scope . 6
8.3.2 Scope changes . 6
8.3.3 Determination elements . 6
8.4 Investigation planning . 7
8.5 Maintaining confidentiality . 7
8.6 Liability caution to deter disclosure . 8
8.6.1 Written caution notice . 8
8.6.2 Verbal caution notice . 8
8.7 No interference . . 8
8.8 Evidence . 8
8.8.1 Document collection and review . 8
8.8.2 Electronic data collection, preservation, analysis and review . 8
8.9 Interviews . 9
8.9.1 Preparations . 9
8.9.2 Conducting an interview . 9
8.9.3 Keeping records of an interview . 10
8.10 Finalization process . 10
8.11 Investigation report . 10
9 Potential remedial measures or improvements .10
9.1 Proposal of remedial measures and improvements . 10
9.2 Interim remedial measures. 11
9.3 A final plan for post-investigation remedial measures . 11
9.4 Proportionality of remediation and improvement measures . 11
9.5 Monitoring and enforcement of remedial measures . 11
iii
10 Interaction with stakeholders .11
10.1 General . 11
10.2 Planning . 11
10.3 Measures for the communication process .12
10.4 Effective communication channels .12
10.5 Government and regulator communication .12
10.6 Self-disclosure to the authorities .12
11 Disciplinary actions .12
Annex A (informative) Guidance on the use of this document .13
Bibliography .24
iv
Foreword
ISO (the International Organization for Standardization) is a worldwide federation of national standards
bodies (ISO member bodies). The work of preparing International Standards is normally carried out
through ISO technical committees. Each member body interested in a subject for which a technical
committee has been established has the right to be represented on that committee. International
organizations, governmental and non-governmental, in liaison with ISO, also take part in the work.
ISO collaborates closely with the International Electrotechnical Commission (IEC) on all matters of
electrotechnical standardization.
The procedures used to develop this document and those intended for its further maintenance are
described in the ISO/IEC Directives, Part 1. In particular, the different approval criteria needed for the
different types of ISO documents should be noted. This document was drafted in accordance with the
editorial rules of the ISO/IEC Directives, Part 2 (see www.iso.org/directives).
Attention is drawn to the possibility that some of the elements of this document may be the subject of
patent rights. ISO shall not be held responsible for identifying any or all such patent rights. Details of
any patent rights identified during the development of the document will be in the Introduction and/or
on the ISO list of patent declarations received (see www.iso.org/patents).
Any trade name used in this document is information given for the convenience of users and does not
constitute an endorsement.
For an explanation of the voluntary nature of standards, the meaning of ISO specific terms and
expressions related to conformity assessment, as well as information about ISO’s adherence to
the World Trade Organization (WTO) principles in the Technical Barriers to Trade (TBT), see
www.iso.org/iso/foreword.html.
This document was prepared by Technical Committee ISO/TC 309, Governance of organizations.
Any feedback or questions on this document should be directed to the user’s national standards body. A
complete listing of these bodies can be found at www.iso.org/members.html.
v
Introduction
Internal investigation is an integral part of organizational management. Internal investigation is a
professional fact-finding process, initiated by or for an organization, to establish facts in
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