Williams & Connolly often conducts internal investigations on behalf of corporate clients in response to “hotline” and “whistleblower” complaints, in-house audits, and other internal company referrals, reporting to management (and in appropriate cases, the board of directors) on how to proceed to resolve those issues. The firm often also assists with follow-on action, such as the submission of voluntary disclosures and the resolution of government actions based on such disclosures.
Our internal investigations have involved many types of allegations, including insider trading, ethics violations, accounting improprieties, tax issues, bribery, and workplace harassment. In addition, we frequently represent major financial institutions in investigations concerning alleged corruption in international projects funded by those institutions. Some of these investigations have been conducted in connection with special committees of boards of directors and/or in connection with derivative litigation. The firm also represents current and former employees who are the subjects of internal investigations.
Because these representations are by their very nature highly confidential, it is not possible to attribute these representations to specific clients. The following list of representative experience, however, provides an overview of the breadth and depth of our practice in this regard.
A representative sampling of some of the firm’s matters in this area include:
- Conducted an internal investigation at the request of an audit committee of a large publicly traded company regarding allegations by a departing senior executive of sexual harassment and Sarbanes Oxley violations by C-suite level executives.
- Conducted an internal investigation for a multinational media company regarding alleged foreign bribery, and represented company in voluntary disclosure to the Department of Justice and the Securities and Exchange Commission; the company was not charged.
- Conducted an internal investigation for a company regarding allegations that an executive attempted to cause the company to reimburse employees for political contributions, in violation of the Federal Election Campaign Act.
- Conducted an internal investigation for a technology company in response to a whistleblower complaint alleging accounting irregularities.
- Conducted several internal investigations for a major defense contractor related to its contracts with federal government entities.
- Conducted an internal investigation for a retail company following whistleblower allegations of consumer fraud.
- Represented financial institution in a review of its internal investigation function, and provided an extensive report on compliance with industry best practices.