1 The New Era of Hiring and Investigating Employees What You Need to Know and When You Need to Know It Reference Materials Littler Mendelson, PC Laura Lindner Julia Arnold Jason Plowman LITTLER MENDELSON, P.C. 111 East Kilbourn Avenue, Suite 1000 Milwaukee, WI Phone:
2 SAMPLE RECOMMENDED INVESTIGATION CHECKLIST Throughout the investigation process, keep in mind the seven steps of an internal investigation: (1) planning; (2) preserving evidence; (3) selecting investigative tools; (4) interviewing witnesses; (5) reaching a conclusion; (6) communicating the results; (7) follow-up. 1. Step One Planning q What is the purpose of the investigation? q What is the triggering event? q Who will be the person with overall responsibility for the investigation? q Will the investigation be subject to the attorney-client privilege? q Will law enforcement have to be involved at any stage? q Is later civil litigation likely? 2. Step Two Selecting Investigative Tools q Reviewing company records q Reviewing paper files and electronic databases of complaints to determine whether similar complaints have been made in the past. q Reviewing personnel files q Searches: desk, lockers, purses, employees, etc. q Electronic data: voice mail, , computer files q Surveillance video q Accessing background check records q Using outside investigators q Using the attorney-client privilege 3. Step Three Interviewing Witnesses q If possible, use two professionals in the interviews; one to ask questions and one to witness and take notes. This is especially desirable when interviewing the subject of the investigation. q Create a written record of each interview q Explain the purpose of the interview
3 q Emphasize that the company takes this matter very seriously and that an investigation is being undertaken which includes witness interviews q Ask open-ended questions q Avoid leading questions q Avoid myths and stereotypes q Ask non-judgmental questions q Avoid the appearance of favoritism q Avoid adopting interviewee s legal conclusions/labels to characterize the behavior in question q Document facts in interview notes q Do not document credibility determinations in interview notes save credibility determinations for final report q Observe and record not only the spoken words of the witness, but also physical and verbal reactions q Determine whether confidentiality is necessary based on the specific facts of the investigation (e.g., witness needs protection, evidence is in danger of being destroyed, testimony is in danger of being fabricated, or there is a need to prevent a cover-up) q If confidentiality is necessary, document the specific need for confidentiality and explain the basis for maintaining confidentiality to the interviewee before asking him or her to refrain from discussing the subject of the investigation with others q Explain that retaliation will not be tolerated and encourage the interviewee to report any retaliatory conduct 4. Step Four Preserving Evidence q Preserve Loss Prevention Surveillance Video? q Have key documents been safeguarded? q Has key electronic data been safeguarded? q Is forensic analysis (i.e., deletion/wiping analysis, metadata analysis, re-duplication, or internet/user activity tracking) necessary? If so, has the analysis been performed? q If electronic data has been erased, can it be restored? q Has physical evidence been stored properly to avoid deterioration? q Have photographs been taken? Date and time of each photograph recorded?
4 q Keep all relevant documentation in a separate file that is maintained and readily accessible in the event that the accuser or accused initiates litigation. 5. Step Five Reaching a Conclusion q Consider credibility determinations. Factors include: Memory Perception Veracity (truthfulness) Corroboration or lack of corroboration Bias of witnesses Consistency of accounts Prior misconduct or lack thereof Plausibility of accounts Review other evidence collected q Identify the policies, procedures, business practices, laws, regulations, and ethics standards that pertain to the allegations q Record your reasoning and steps taken 6. Step Six Communicating the Results q Communicate results of investigation to complaining employee q Communicate results of investigation to victim if different from the complainant q Evaluate whether communication to law enforcement agencies is appropriate q Take steps to ensure communication of information only to those who have a need to know q Communicate the closure of the investigation to the subject of the investigation, whether the allegations were substantiated and, if appropriate, whether any disciplinary action is forthcoming 7. Step Seven Follow Up q Maintain separate records of investigation q Take steps to ensure that no retaliation is taken against complaining employees q Audit internal operations which allowed event to take place
5 q Revise operational and personal procedures and policies as appropriate q Evaluate the effectiveness of the investigation itself q Create a single, definitive and legible draft of notes
6 SAMPLE INVESTIGATION PLANNING WORKSHEET INITIAL ANALYSIS MATTER: COMPLAINANT(S): DATE OPENED: I. General Summary of Complaint: Written complaint attached _ Summarized below II. List of Allegations (attach separate sheet(s) if necessary)
7 III. Review of Documents / Evidence Pertinent employer policies Police reports, official records Employee files and evaluations Pictures, charts, data Incident reports, memos, correspondence Evidence from project files Relevant or computer files Performance ratings/ other data Other materials (list): Other Tasks or Resources Needed:
8 WITNESS WORKSHEET 1. WITNESS NAME & POSITION REASON FOR INTERVIEW DATE SCHED. (COMPLETED x ) LOCATION OF INTERVIEW (Add additional witnesses as necessary)
9 SAMPLE WITNESS INSTRUCTIONS Who you are and what you are doing My name is. I am here to conduct a workplace investigation. Since this is a workplace investigation, it is a serious matter and is being conducted in accordance with company policy. Our objective is to find out what happened here so we can advise management accordingly. To accomplish that, we would like you to assist us and share your side of the story. We very much appreciate your time and cooperation. I will not mislead you or lie to you. I expect that you will not lie to me. Lying in the course of the investigation can lead to serious consequences. I will be taking notes because I want to make sure that I document what you say with complete accuracy. Your job You expect that you will cooperate fully, with complete candor, and respond to all questions and requests honestly. Is that understood? If you do not understand a question, please let me know, and I will clarify it. If you do not ask for a clarification, I will assume you understood the question. I am interested in what you have to say based on your own personal knowledge. Please do not speculate. If you do not know the answer to a question, please say so. Don t guess. Or if you are guessing, please let me know. Confidentiality 1 We will be handling this investigation in as confidential a manner as possible because [insert basis for requiring confidentiality e.g., witnesses need protection, evidence is in danger of being destroyed, testimony is in danger of being fabricated, or there is a need to prevent a cover-up]. Information we are gathering will be shared only an absolute need to know basis. Retaliation We will not tolerate any type of threat or retaliation against anyone who reports a violation or cooperates in an investigation. If you receive any such threats, or feel uncomfortable in any way, please advise me or immediately. Other instructions Please do not ask me who reported a violation or who else may be cooperating in the investigation. We want to protect the reputation of all parties involved in the investigation. Please do not draw any conclusions as a result of this interview. This interview is only part of the investigation. My goal is to obtain truthful and the most accurate information possible. If later you happen to remember anything that you couldn t recall here today, or you want to supplement or correct something you said to me, please call me at. 1 Again, a confidentiality requirement should be imposed on a case-by-case basis. If the company determines that confidentiality is necessary in a given investigation, the investigator should instruct employees not to discuss the investigation with other employees after explaining why confidentiality is necessary based on the type of investigation and/or the circumstances of the investigation.
10 SAMPLE GENERAL INTERVIEW FORM OPENING QUESTIONS: How long have you worked for the Company? Who do you report to? Tell me a little about the general environment of your department. Tell me about your work environment in general and describe what happened: Nature of allegations: Dates and locations of alleged incidents: To whom were the allegations first reported? When were they reported, and how?
11 Where did the incident take place? When (date and time) was the incident? Did you witness the alleged incident? Where were you? Who else was present? What happened? What did you see?
12 What (word for word, if possible) did you hear? Did anyone else do or say anything during the incident? Is there anything else that you recall about the incident? [Repeat and use wherever appropriate] Is there anything else you would like to add about this incident? Do you have any theories as to the reason or motive for the incident?
13 Have you had any conversation(s) with anyone about anything related to the incident? Do you know whether anyone else has, or claims to have, any information about the incident? (Interview all identified witnesses or potential witnesses if possible.) Are you aware of any documents (writings of any kind) that relate in any way to the incident? Are you aware of any physical evidence that may relate in any way to the incident? Are you aware of any electronic evidence that relates in any way to the incident? Are you aware of any similar incidents?
14 Is there anyone else that you think I should talk to? Are there any other files, records, or objects that you think I should examine, or that might refresh your memory? Is there anything else, no matter how remote, that I should know about? Is there any other evidence or fact that you believe would help us resolve this? Here is my card. If you think of anything else, no matter how trivial, or if anything at all comes up, please call me. Thank you for your cooperation. [Remind interviewee that confidentiality is required and that retaliation will not be tolerated.] Name of Investigator: Date:
15 SAMPLE INTERVIEW FORM FOR THE COMPLAINANT [Review confidentiality and no retaliation with Complainant.] How long have you worked at (company)? Tell me about a typical day on your job. How do you know the subject of the investigation? Tell me about your working relationship with the subject of the investigation. How often do you work together? Explain the specific incident that occurred that prompted your call to me today (If touching was involved, ask for specific areas of the body. If it was a verbal incident, ask for specific details regarding particular quotes). When/where/date did the specific incident occur? Were there any witnesses present?
16 Did you inform the Subject of the investigation to stop doing the behavior/action he/she was doing? If yes, what was his/her response? Did the behavior/action continue? Are you aware of anyone else who has been the subject of this or a similar action/behavior? Did you inform your immediate manager of this incident? Have you informed anyone of this incident? If so, who/when? Were there prior incidents of this nature? When/where/date did the prior incident(s) occur (If touching was involved, ask for specific areas of the body. If it was a verbal incident, ask for specific details regarding the particular quotes)? Were there any witnesses present during those incidents? Did you inform the subject of the investigation to stop doing the behavior/action he/she was doing? If yes, what was his/her response? Did the behavior/action continue?
17 Are you aware of anyone else who was the subject of this or a similar action/behavior? Did you inform your immediate manager of those incidents? Did you inform anyone of those incidents? If so, who/when? Do you have any documentation/paperwork regarding the current or past incidents that you can fax/mail/ to me that you believe to be relevant? What action would you like to have taken? Is there anything else you d like to add? Here is my card. If you think of anything else, no matter how trivial, or if anything at all comes up, please call me. Thank you for your cooperation. [Ask Complainant to write a statement re-capping the discussion and discussion and provide it to you.]
18 PRE-INTERVIEW CONSIDERATIONS FOR INTERVIEWING THE SUBJECT OF THE INVESTIGATION Prepare for the investigation meeting with the subject of the investigation. This meeting should take place in private, although as the investigator, you may arrange to have a witness present as appropriate. The investigator should outline the allegations in advance to ensure that all subjects are discussed. Provide the subject of the investigation with a copy of the harassment, discrimination, equal employment and/or general misconduct policy as appropriate. Emphasize the organization s commitment to enforcing the policy. This step should be followed even if it is suspected that the allegations are not true. Answer any pre-interview concerns or suspicions that the subject of the investigation person may have about the investigation. Advise the subject of the investigation generally about the investigation and policies against retaliation. Ask direct and detailed questions based on information provided by all witnesses, such as those on the following interview form.
19 SAMPLE INTERVIEW FORM FOR SUBJECT OF INVESTIGATION OPENING FOR THE INTERVIEW: 1. Thank the person for coming in. Inform subject of the investigation that the purpose of the meeting is to talk about allegations of workplace misconduct made against him/her. 2. Explain the following to the subject of the investigation: No decision will be made until all the information has been collected. This is your chance to tell your side of the story. Your confidentiality is required. Retaliation is prohibited. OPEN ENDED QUESTIONS: Tell me about your working relationship with. Were you and the complainant working together on the date(s) complainant says the harassment or other misconduct occurred? Do you recall any interaction with complainant on those dates? If so, what was the context of the interaction? Were there any witnesses present? (All identified witnesses should be interviewed.)
20 What was the substance of any conversation between you and the complainant? Expect an adamant denial. For each denial, request that the harasser identify corroborating witnesses or evidence, and detail any alibi. If the subject of the investigation acknowledges any conduct, ascertain and document what occurred. Try to get as many details as possible, even though this may be uncomfortable for the subject of the investigation. Use additional pages if necessary. Ask open ended, non-judgmental questions, such as: Did the subject of the investigation engage in the alleged conduct? If so, describe the circumstances and frequency of the conduct? Did the subject of the investigation threaten the complainant in any way? How long was the incident? For example, a few seconds or five minutes? Where did the incident take place?
21 Were there any witnesses to the incident? If so, who were the witnesses? How did the complainant respond to the incident? Did he or she make any effort to bring it to a halt? How did the subject of the investigation feel about the incident at the time it occurred? Did the subject of the investigation do or say anything that could have been misunderstood or could be intentionally misrepresented? Ask the subject of the investigation about his/her beliefs or suspicions as to why the reports or complaints have been made (such as ulterior motives, prior consensual relationships, retaliation by the complaining employee, attempts at job security in the face of poor performance evaluations, etc.).
22 Did the complainant engage in any conduct which the subject of the investigation felt was inappropriate or made the subject of the investigation feel uncomfortable? Has the complainant ever said or done anything that would lead the subject of the investigation or others to believe that the complained-of conduct was not unwelcome? What is the level of supervision between the subject of the investigation and the complainant? How frequently do the subject of the investigation and the complainant work together? Has the subject of the investigation previously been accused of discrimination or other misconduct? If so, what were the circumstances? Other:
23 [Advise that if the evidence establishes misconduct, the organization will take appropriate disciplinary action against the subject of the investigation and the complainant will be fully informed that the investigation has been completed, and whether the allegations were substantiated. The complainant, however, is not provided with any information about the specifics of any disciplinary actions, but should be informed that the company is addressing the issue appropriately.] Here is my card. If you think of anything else, no matter how trivial, or if anything at all comes up, please call me. Thank you for your cooperation. [Remind interviewee that confidentiality is required and that retaliation will not be tolerated.] Interviewer: Date:
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