Internal Investigation Procedure

Internal Investigation Procedure

The purpose of the Internal Investigation Procedure is to formalize an Internal Investigation process by the Security Department and to:
a. Guarantee the quality of the services provided by Security Department and the professionalism of the Company’s investigators
b. Provide Company’s investigators with a common repository in terms of language, rules of conduct and methods to guarantee that the investigations are carried out with professionalism, in a standardized approach.

This procedure applies to the entire Company personnel (employees, including leased employees, directors, executives and shareholders), as well as to contractors and dealers who have a business relationship with the Company, if the event being investigated has connections to Company employees, directly or indirectly, with the support of a third party.
To avoid any potential conflict/ overlap with the provisions of the disciplinary process, it is essential to be known that the Internal Investigations Procedure applies in the following cases:
a. When the nature of the offense is serious, as offenses are defined by the Company Guide with Internal Rules
b. Any case of conflict of interest, as defined by the Company Guide with Internal Rules and by the Ethics Procedure
c. Anytime when the value of the theft/ fraud exceeds 1000 EUR
The list of offenses mentioned above is not exhaustive and does not cover all kind of offenses that may be subject of the Internal Investigation Procedure. The Fraud and Ethics Committee is the final decision maker on whether a fact/offense should be investigated according to this procedure or to the disciplinary process.

CONTENT

1. OVERVIEW
1.1 PROCEDURE OWNER
1.2 CLASSIFICATION
1.3 APPLICABLE REGULATIONS
1.4 RELATED [COMPANY] NORMS AND PROCEDURES
1.5 OBJECTIVES
1.6 AUDIENCE AND SCOPE
1.7 DOCUMENT SUPPORT
2. DEFINITIONS & ABBREVIATIONS
3. CONSIDERATION AND PRINCIPLES
3.1 COMPANY’S ETHICS PROCEDURE
3.2 CODE OF ETHICS FOR INVESTIGATORS
3.3 LEGAL CONSIDERATIONS
3.4 ETHICAL CONSIDERATIONS
3.5 CULTURAL CONSIDERATIONS
4. WORK FLOW AND GUIDELINES
4.1 GENERAL GUIDELINES
4.2 LEGAL GUIDELINES
4.3 ETHICAL GUIDELINES
4.4 GUIDELINES RELATED TO INVESTIGATIONS STAFF
4.5 INITIATION OF FRAUD INVESTIGATIONS
4.6 INVESTIGATION FUNCTIONS
4.7 INVESTIGATION RESOURCES
4.8 GUIDELINES ON THE CONDUCT OF AN INVESTIGATION
4.9 GUIDELINES ON GATHERING AND HANDLING EVIDENCE
4.10 GUIDELINES ON ASSETS RECOVERY
4.11 GUIDELINES ON THE CONCLUSION OF AN INVESTIGATION
4.12 ARCHIVING
5. RESPONSIBILITIES MATRIX/ TASKS DETAILS
6. EXCEPTIONS
7. FINAL CONSIDERATIONS
7.1 DISCIPLINARY ACTIONS AGAINST PROCEDURE VIOLATION
7.2 DOCUMENT REVISION
8. ANNEX 1 – CODE OF ETHICS FOR INVESTIGATORS

Pages: 19

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