Contents1 Overview2 Triage – what do I do first?2.1 Internal reporting2.2 Crisis management and response planning2.3 Identifying all of the stakeholders3 Investigation issues3.1 The decision to investigate3.2 Preparing an investigation plan3.3 Legal professional privilege and investigations3.4 Protecting and managing whistleblowers3.5 Confidentiality of investigations3.6 Document preservation3.7 Document collection3.8 Responding to dawn raids3.9 Dealing with witnesses3.10 Dealing with employees who are implicated3.11 Director and officer duties concerning investigations4 Notification and reporting requirements4.1 ASX disclosure requirements for listed companies4.2 Breach reporting requirements for AFS licence and under other licenses and permits4.3 Requirement to notify the police of serious indictable offences4.4 Issues under finance documents4.5 Commercial partners and compliance certificates and undertakings 4.6 Considering notifying insurers4.7 Immunity applications for cartel conduct4.8 Voluntary self-reporting to authorities5 Cross-jurisdictional issues5.1 What jurisdictions might be in play?5.2 Disclosures to regulators in foreign countries?5.3 Other issues that might arise cross-borders6 Addressing the conduct6.1 Stopping payments and money laundering offences6.2 Identifying and remediating root causes6.3 Accountability and consequence management6.4 Remedy7 Emerging stronger Contact us
