10 Steps to Conducting a Successful Internal Investigation

Conducting an investigation is a significant responsibility and among the most important work you will do as a manager.


An essential tool for any manager is the ability to conduct a thorough and proper investigation when needed. Investigation is a significant responsibility and among the most important work you will do. It also separates you—a manager—from your subordinate employees. The following 10 steps can help you lay the groundwork for a reasonable, timely and successful investigation.

Step 1: Define the Problem

Defining the problem or allegation you need to investigate is a crucial part of understanding how to tackle the investigation. Ask yourself, is the investigation going to pertain to a complaint, an accusation, employee misconduct or a rumor? Is it a simple issue such as investigating a callout or a more complex issue like an allegation of sexual harassment?

Step 2: Research the Company Policy

An organization should have a well documented and communicated corporate policy or procedure, addressing rules of acceptable behavior and practices through a policy and procedure manual or handbook. If an organization lets a manager simply “wing it” without a manual, it’s setting itself up for a risky practice that could potentially lead to discrimination issues and legal liability down the road. Equally as important as having a policy manual is to have an effective means to communicate those policies to employees so they understand what is expected of them and the ramifications for not following policies. If this communication is successfully executed, employees shouldn’t be surprised about the outcome if they violate a company policy. As a manager it’s your job to know the policies you’ve been empowered to enforce, and to remind employees that such policies exist.

Step 3: Create a Framework for Your Investigation

This is your roadmap. Start with the person making the complaint, then move on to the accused and any witnesses. Witnesses will have observed the issue or action that gave rise to the complaint or have firsthand knowledge about the issue or complaint. This list will likely become more comprehensive after you interview the complainant and/or the accused.

Next, you need to determine the kind of information you’re seeking in your investigation. You want your witnesses to tell a story, so prepare your questions accordingly. You should use questions beginning with who, what, when, where, why or how, and remember you can never be too prepared for an investigative meeting. Taking the time to go through this process maximizes your efforts and reduces the odds you’ll have to recall witnesses for information you forgot to ask. Stay focused during your witness interviews and remember things are not always as they seem. Your preparations aside, you must also be ready to ask new questions on the spot based on what you learn from the interview. Once you have performed your due diligence with respect to the issue, you can roll up your sleeves and begin to really investigate

Step 4: Interview the Complainant, the Accused and the Witnesses

This is the most visible part of the investigation and also where many managers tend to begin their investigation without following steps 1–3. Don’t make that mistake—be prepared.

Begin with the basics. Explain to the interviewee why they’re involved in the investigation. Employees are generally nervous about being involved in an investigation and a nervous witness just makes your job more difficult. To ease the situation, ask the employee to describe the events as they remember them. It’s at this point that your role as interviewer shifts to active listener and note taker. A word of caution on note taking: write down only the facts. It is acceptable to note body language or to document a nervous witness; however, avoid inserting assumptions, feelings, interpretations, frustrations or premature conclusions.

This content continues onto the next page...