Business & corporate groups
Investigations in companies, corporate structures or joint ventures – from the assessment of a report through to reporting to the management board or supervisory board.
Internal Investigations
Internal investigations according to international standards.
When there is a suspicion of serious misconduct or criminal offenses within a company, a mere “clarification of the facts” is no longer enough. What is needed is a structured internal investigation – legally robust, traceable and reliable.
I conduct and support internal investigations, among other things on the basis of the United Nations Investigation Manual and comparable international standards.
Typical reasons for internal investigations
Internal investigations are usually required when internal or external indications of serious breaches of duty or criminal offenses arise:
- Suspicion of corruption or bribery
Indications of improper payments, invitations or benefits in connection with contracts. - Fraud, breach of trust, asset shifts
Irregularities in accounting, unclear cash flows, “side structures”. - Reports from whistleblower systems
Anonymous or open reports from employees, suppliers or customers.
- Compliance violations with criminal-law relevance
Cartel arrangements, export control violations, sanctions breaches, data protection incidents. - Suspicion of organized structures
Indications of coordinated conduct by several individuals, for example in purchasing, sales or logistics. - Sensitive business areas
Areas with an increased risk of corruption or security issues, such as aviation or other security-relevant sectors.
Approach in internal investigations
Internal investigations must be legally sound, documented in a traceable way and at the same time sensitive in their handling of the people involved. In doing so, I follow international standards – including the United Nations Investigation Manual.
- Clarifying mandate & structure
Clarification of objectives, scope, reporting lines and confidentiality (Legal, Compliance, HR, supervisory bodies). - Investigation plan & document/data capture
A structured plan, review and preservation of relevant documents and data. - Interviews & hearings
Preparation, conduct and documentation of interviews with whistleblowers, witnesses and respondents.
- Assessment & legal classification
Allocation to possible criminal offenses and assessment of labor law and regulatory consequences. - Reporting
Structured reports for management, supervisory bodies, authorities or contractual partners. - Interface to criminal proceedings
Coordination with law enforcement authorities, decisions on self-reporting or disclosures, and support in parallel proceedings.
Analytical perspective: the analytical lens for internal investigations
Internal investigations are rarely linear. Hints, documents, interviews, internal politics and external expectations overlap. For results to be sustainable, it is not enough simply to collect information and write reports.
I work with an analytical lens that considers several levels at the same time and brings them together into one causal overall picture:
- Operational level – concrete events, actions and processes.
- Tactical level – recurring patterns, exploited loopholes, typical modes of operation.
- Strategic level – goals, interests, lines of power and governance structures.
- Psychological level – motivation, pressure, loyalties, conflicts and fears.
- Causal level – the actual chains of cause and effect behind what has happened.
Along these levels, competing hypotheses are developed and tested. This makes it much easier to separate noise, narratives and self-interest from robust findings.
Backward & Forward: origins and developments
From this analysis two movements emerge:
- Backward causality – reconstructing the actual origin of the situation: how did it come about, who played which role, where did structures fail or work?
- Forward risk architecture – modeling realistic scenarios and risks: for management, supervisory bodies, authorities, regulators and – where necessary – the public.
The result is internal investigations that go beyond the mere state of the file and create a robust basis for decisions – up to and including the question of whether, how and to what extent to cooperate with law enforcement authorities.
My role in internal investigations
I develop the investigation strategy, structure hypothesis spaces and personally conduct sensitive interviews and hearings. Additional operational resources – for example surveillance or IT forensics – are only brought in where substantively necessary and remain independent specialized service providers.
This keeps the strategic steering of the investigation legally independent, while operational measures are used in a targeted way where they make sense both legally and factually.
A detailed description of my analytical lens can be found in the Dossier Analytical Working Method.
A compact overview specifically on internal investigations is provided in the Short Dossier Internal Investigations.
Sectors and contexts
Internal investigations arise in a wide variety of industries – but they are particularly sensitive in regulated sectors and companies with an international footprint.
Aviation & aircraft manufacturers
Internal investigations in airlines, airports, aviation organizations or aircraft manufacturers – for example in cases of suspected corruption in procurement, cargo crime or allegations of espionage.
International context
Investigations involving several jurisdictions, different cultures and varied regulatory requirements – reporting and communication in German or English.
Discreet initial consultation
If you are considering a possible internal investigation or already have indications of serious misconduct, a structured first step is crucial.
I am available for a confidential, structured initial consultation – if desired together with internal or external colleagues (Legal, Compliance, HR).
Contact:
E-mail: martin@heynert.com
Phone: Office +49.391.5982-243, Mobile +49.171.4135269