INTERNAL INVESTIGATIONS IN A POST-COVID-19 ERA
The coronavirus (COVID-19) pandemic has triggered a series of changes in work culture, which have in turn driven a shift in the way investigators approach internal investigations. Some of these changes were temporary and mostly restricted to the initial chaotic months of the pandemic in early 2020, such as the rapid onboarding of new suppliers and furloughing employees.
Others, while initially makeshift, are now a more permanent feature of how many companies conduct business post-COVID-19 – for instance, large numbers of employees working remotely from home, in some cases on their personal devices, and replacing business travel with video calls.
One implication of this change in work culture is an increased opportunity for remote employees to engage in corrupt behaviour, financial crime and other misconduct. With the absence of in-person oversight and visibility from colleagues, more autonomy from remote working, and a decrease in legal teams’ visibility and ability to investigate suspected issues in person, it has become easier for employees to engage in misconduct and harder for organisations to detect issues.
A high-profile example of this occurred in November 2021, where shortly before moving to a competing organisation, a Pfizer employee allegedly uploaded over 12,000 files, including documents containing confidential information related to the COVID-19 vaccine, to a personal Google Drive account and personal devices. When confronted, the employee allegedly produced a ‘decoy’ laptop and misled Pfizer about what she took, how she took it, when and why she did it, and where those files (and possibly others) can be found.
Apr-Jun 2022 issue
S-RM