Step Two: Evaluate the Allegations or Suspicions

The next step is to evaluate the allegation or suspicions – the red flags – to see if it makes sense to proceed.

Considerations include:

  1. Are the allegations or suspicions plausible, based on other available information?
  2. Are the allegations or suspicions serious enough to justify the time and expense of an investigation?
  3. Are the allegations or suspicions specific enough to identify leads and draft an investigative plan?
  4. Are necessary documents and witnesses accessible?

Determine if there have been prior similar complaints or investigations, and if so, obtain and review the relevant files.

Allegations from a whistleblower can be tested by looking for the red flags of the alleged offense.  For example, if a bidder complains  that it was the victim of a bid rigging scheme, collect the relevant bidding data as promptly as possible and look for the indicators of the alleged scheme.

The whistleblower may also be recontacted to obtain additional information about his or her allegation.

If the above factors are not met, consider:

  1. Recording the allegations in the event that similar allegations are received in the future, or
  2. Referring the matter for an audit of the affected function, or
  3. Referring the allegations to operational personnel for their use to design improved controls or procedures.