Summary

Hahn Loeser has conducted multiple compliance investigations, including compliance investigations for companies among the Fortune 100. These investigations have involved alleged violations of both internal ethics policies, as well as state and federal law. Hahn Loeser’s experience makes it uniquely positioned to provide clients with not only the expertise necessary to conduct external compliance investigations, but also proactive advice for clients’ current practices and policies to help ensure uniform enforcement and investigation and to avoid potential whistleblower claims by ensuring efficient and effective investigation and resolution of compliance complaints.

Representative investigations include:

  • Whether an employee improperly disclosed a customer’s proprietary information to another customer
  • Whether employees executed a contract despite explicit instruction from the company’s legal department that the contract was illegal, and whether those employees obstructed the subsequent investigation into that contract, including falsifying evidence
  • Whether employees improperly caused the company to realize revenue and artificially inflate earnings
  • Whether a high-level employee for one of the company’s accounts failed to disclose that he caused the company to hire a contractor that employed his son
  • Whether employees improperly gave gifts to public employees
  • Whether a subcontractor employed by the company had overcharged for work performed on a state- and federally-funded construction project in violation of state and federal false claims law.

Hahn Loeser attorneys have substantial experience in techniques necessary for effective compliance investigations, including:

  • Securing relevant evidence, including employee e-mails, instant messages, personal computer files, and computers themselves
  • Efficient review of documents, including large quantities of electronically-stored information
  • Quickly identifying key documents and providing them to proper company executives and general counsel to facilitate efficient decision making
  • Interviewing employees, including, but not limited to, high-level executives
  • Working with external accounting and other experts when necessary to make proper compliance and legal decisions
  • Drafting memoranda and reports that summarize the investigation, recommend next steps, and suggest best practices going forward.