Internal Investigations: The truth may hurt, but not as much as the alternatives

Imagine, if you will, the following scenario. You're standing on a petrol station forecourt filling your tank, watching the display as the total climbs and climbs. You hang up the nozzle, grudgingly pay at the desk, return to your car and drive off. And that's when you notice - a third of the fuel you've just paid for somehow never made it into your tank...

Internal Investigations: 

The truth may hurt, but not as much as the alternatives

For global organisations - commercial and humanitarian - operating in developing countries, the cost of staff misconduct can be staggering, not just in money and reputation but also in human misery. While terms like 'internal investigations' may conjure images of Big Brother colleague-snooping, in reality training key staff in the basics of competent investigation can have a profound impact on organisational culture, where a commitment to transparency can build a collective resistance to malpractice.

This, in a nutshell, is exactly the scenario that mobile communications companies in Africa are faced with as they expand their networks way beyond the reach of electricity supply grids. In some African countries up to 80% of cellular towers have no access to reliable electricity, relying instead on diesel generators and batteries. One industry survey put the amount of fuel destined for tower sites that disappears en route (or from on-site tanks) as high as 35% - imagine it: that's the equivalent of one in every three tankers being stolen as it leaves the depot. 

But in reality, tackling issues of this kind is nothing like as simple as tracking down missing tankers; the theft actually occurs in smaller amounts at pretty much every stage of the purchase, transportation and storage chain, and the culprits are just as likely to be on the inside as the outside, sometimes involving the very security staff on the ground who are paid to protect the company's assets.

Fuel theft is just one of a very long list of challenges faced by global companies and humanitarian organisations who operate in many of the worlds trickier environments. Supply chain and procurement are obvious targets, but the problems go far wider and far deeper.

"We obviously get to hear the horror stories," says Sean Buckley of global compliance and investigations group Osaco who have a network of professional investigators and trainers working for clients across the humanitarian and commercial sectors. "I'd say that most of what we deal with falls into three categories. There's administrative issues like fraud, embezzlement, procurement and supply chain scams. Then there's physical security stuff, such as theft, attacks on property or staff, kidnapping, road traffic or other accidents. And then there's what you could broadly call human interaction issues, such as abuse of authority and position, harassment and discrimination, right through to violence, sexual exploitation and abuse."

While most organisations of any size will have a raft of oversight and compliance type structures in place - codes of conduct, standard operating procedures, reporting channels, disciplinary protocols or even whistle-blowing hotlines - the degree to which staff behaviour is monitored and, in cases of alleged misconduct, investigated and pursued, varies greatly. It's a highly complex issue, particularly for locally employed staff working in remote locations under difficult circumstances, where conflicts of interest, power structures, family loyalties, local culture and the sheer pressure of the general environment can exert huge pressures on people.

Many international companies and most of the larger humanitarian organisations and agencies have their own centralised investigations, standards or compliance units, says Buckley. "They'll have a staff of investigators - of pretty variable quality and experience it has to be said - who are called in by regional management or parachuted in from above at head office to follow up on reported problems."

However the cost of running a dedicated investigations team is prohibitive for most mid-sized or smaller operations. "Unfortunately it's quite common for investigations to be carried out ad-hoc by untrained staff, maybe from HR or accounts or wherever," observes Buckley. "These are often people who just aren't adequately prepared to deal with the situation and conduct a competent investigation - let alone handle the obvious pressures of investigating their own colleagues, especially their superiors."

In more serious cases it's increasingly common to bring in external professional investigators like Buckley, not just to pursue the matter at hand but to train in-house staff in the basics of investigation. "It makes obvious sense to use dedicated investigators," argues Buckley, "either from outside or by training and nurturing that skillset internally. While every case is obviously different, essentially the methods that any professional investigator will use are pretty much the same regardless of what they're dealing with, and these can be taught very effectively."

The Danish Refugee Council is one example of a large international organisation that has taken a highly proactive approach to dealing with staff misconduct and trained a significant number of regular staff as investigators. Born in response to the post WWII European refugee crisis of the mid-50s, the DRC now functions as an umbrella humanitarian organisation with operations in over 35 countries throughout the world - including some of the most troubled areas of the Middle East and Africa.

"When you work in the humanitarian sector under extremely difficult circumstances, as we do, you have to accept that there will be misconduct," says Niels Bentzen, DRC's global specialist lead on humanitarian accountability. "We may not like this but there's no way around it, so we have to increase the quality of how we deal with it.

"We managed to develop a well-structured and very relevant internal training course for what I refer to as 'barefoot' investigators'," explains Bentzen - a reference to Chinese farmers given rudimentary medical and paramedical training to provide minimal but effective basic healthcare in remote rural areas. "The trainees shouldn't claim they are able to conduct complex investigations, but what they can do is conduct simple investigations as near to the problem as possible under the circumstances."

"When it comes to in-house training, no-one's pretending you can make seasoned professional investigators with a five day course," says Osaco's Sean Buckley, "but our aim is to get people grounded in a basic methodology for competent investigation, with minimal technical jargon, keeping it simple. It's not glam...it's certainly not CSI - we're nowhere near good looking enough! We place a lot of emphasis on basic process: making an initial assessment, and then planning and documenting at every stage. It's amazing how often people will attempt to investigate even quite serious allegations without any paper trail...that's just a disaster."

And, according to Buckley, this kind of incompetence is costly on many levels. "A half-assed, poorly conducted investigation is almost as damaging as not investigating at all. It sends all the wrong messages. For a start everyone involved is entitled to the same protection - witnesses, victims, complainants and the subject - so it's vital that a matter be investigated fairly, transparently and objectively, and that takes training. You do things to the same high standard regardless of the severity of the allegation. Part of what we teach people is also to recognise when they're out of their depth and in need of professional backup.

"There's too much at stake, not just the obvious like money and assets. I've seen good people lose jobs and have careers ruined on the flimsiest of evidence due to poor investigation. The more extreme cases involving abuse of position, exploitation of the vulnerable and sexual abuse really demand a professional standard of investigation. You're dealing with human lives, misery and suffering: surely that deserves proper handling?"

According to fellow Osaco investigator Dominic Smyth however, there are also wider implications for organisations that don't adequately investigate misconduct. "It sends a dangerous signal, not just to actual or potential perpetrators, but to everyone in the organisation as a whole. It says 'we don't really care'...with the obvious implication that if we'll turn a blind eye - or at least an incompetent one - to basic misconduct such as fraud and theft, then what else will we turn a blind eye to? That's a deeply damaging and corrosive message within the internal culture.

"This isn't about creating a 'Big Brother' scenario," asserts Smyth, "but people have to know they'll be held accountable for their actions, and people need to see management's intent made clear in action: we have a code of conduct that we've all signed up to; if any of us step outside of it we can expect the matter to be investigated and dealt with properly."

According to business and brand development consultant Marc Phelps, leaders have to pay more attention to influencing internal culture.  "Commercial and humanitarian organisations clearly have different raisons d'etre and cultures but, people being people, they share many of the same problems when it comes to staff misconduct," he says. The two sectors may have fundamentally different primary concerns - reputation and the fear of it being tarnished has historically meant far more to humanitarian organisations than to big business, where the primary concerns are profit and share value - but these concerns can lead to the same thing happening. "You can see a culture of resistance that makes people reluctant to look too closely at what's really going on - the fear of opening a can of worms," says Phelps, "but this culture is obviously at direct odds with their publicly stated aims and code of conduct.

"Many commercial businesses and brands now accept their primary focus can't just be the bottom line. Just as reputation damage has always been a primary threat for humanitarian organisations, businesses are finally beginning to see that a loss of standing with their critical audience or sponsors does more than put them in the spotlight of shame, but represents a direct existential threat no matter how large they are."

And on that point, it would also be a mistake to think the problems of internal malpractice are limited to developing countries or just to the far-flung outer reaches of big organisations. "We conduct as many investigations at HQ level as we do in the field," observes Osaco's Dominic Smyth. "Look at what's been going on at FIFA, or the bribery scandals at Siemens a few years back; in their case, while the payment of bribes took place mainly (but not exclusively) in developing countries, the cash and the officials carrying it around the world in briefcases came out of their German headquarters. The motivation and the action both came from board level; it was company strategy, not an anomaly. Fraud, supply chain theft, sexual and other kinds of harassment, conflicts of interest and the lack of internal capability for investigations - these are definitely issues that are right under our noses and not 'out there' somewhere."

Investigations training, such as the programme put in place within the DRC, is just one of many tools that can be deployed in tackling the gap between an organisation's stated intention and its on-the-ground culture. "'Get them on the way up' is a vital element in creating cultural change," asserts Smyth. "Anything that makes it the norm to look closer, that encourages staff to flag up concerns without fear of consequences and that instils some faith in due process has to be a good thing, as DRC have demonstrated."

"I would agree that in most institutions, information about internal misconduct is unwelcome," says DRC's Bentzen, "firstly because it creates a lot of problems and extra work, and secondly it may really set you back in your efforts. Our intention is therefore to build a better understanding that humanitarian work, although inspired by idealism, is not ideal and that we must expect that there will be misconduct. What really matters is an institution's ability and will to address it.

"In our experience, those who are trained become ambassadors in their local areas, and although this can shed light on how little their managers know about the whole issue, the training has brought about a better understanding of the importance of investigations and the principles involved."

This kind of culture change is something that all widely distributed organisations have to take more seriously, according to Phelps. "It's not enough to point a blaming finger at individuals who go astray. Any culture by its nature encourages some kinds of actions and discourages others. A business culture with a strong moral compass will naturally create barriers to bad practice - a kind of collective natural resistance to the actions of a few flawed individuals. At the same time it can cultivate the kind of responsibility where investigation and enforcement become rarely used implements."

And, says Osaco's Sean Buckley, part of this culture shift comes from a clear recognition of the costs - monetary, reputation and human - of misconduct and the ongoing collective failure to investigate and tackle it. "The question then becomes reversed: not 'can we afford to address it?' but 'can we really afford not to?'"   n