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Effective compliance management systems require the installation and maintainance of measures within the company in order to counter any compliance violations and misconduct. For this purpose the instrument of internal investigations is essential. Internal investigations are complex, as they take place within the company and, in worst case reveal criminal offences. It is not unusual for internal investigations to be carried out in parallel with ongoing investigations by law enforcement authorities to gain new options under criminal procedure law (e.g. secondary action, adhesion proceedings). Internal investigations involve more than a simple check of employees who are allegedly economically delinquent. Investigations go beyond the question of whether an offence has been commited. Investigations have the purpose of documenting and reviewing existing processes and examine, whether these may have provided employees with an incentive to commit criminal offences. In addition, internal investigation also have the purpose to review the implemented compliance management system and to serve as a cause to improve the system by revealing problems and thus to prevent future misconduct. The use of external consultants to conduct internal investigations is not only recommended for companies that lack the necessary capacities and technical skills of a compliance department with a large number of employees. This approach is also recommended for companies with more extensive compliance departments for the reason of faster processing. Moreover, especially in the case of employee interviews with specialized lawyers, it can be guaranteed, that legally usable results are obtained.
