Conducting corporate internal investigations.

Internal investigations of possible illegal or improper conduct by corporations have become an increasingly important exercise of good corporate governance in the United States. In the wake of the major corporate scandals involving Enron and WorldCom, the US Congress enacted tougher corporate accountability standards through the Sarbanes–Oxley Act of 2002 (‘Sarbanes–Oxley’).1 The financial statement certification and increased Board of Director responsibilities set forth in Sarbanes–Oxley have contributed to the rising importance of corporate internal investigations. In addition, US regulators at the federal, state and local levels have fostered an emerging culture of corporate compliance by giving credit to companies that take voluntary steps to investigate, disclose and halt any illegal or improper conduct. This paper describes various best practices that have emerged in the US for conducting corporate internal investigations, particularly those involving high-profile matters that are of paramount importance to the financial status, risk exposure or reputation of the company sponsoring the investigation.2International Journal of Disclosure and Governance (2007) 4, 297–308. doi:10.1057/palgrave.jdg.2050065 [ABSTRACT FROM AUTHOR]