1 of 35 © 2017 Association of Certified Fraud Examiners, Inc.

Building the Perfect Investigations Team to

Find, Eliminate, and Remediate Misconduct

Lisa Chafin

Financial Investigations Senior

Manager, Internal Audit

Google, Inc.

Andrew Price, J.D.

Senior Counsel

Google, Inc.

2

PAVING THE PATH TO

THE TRUTH

Building the Perfect Team to Investigate,

Eliminate and Remediate Misconduct

3

Have you ever worked on an investigation team?

What makes it painful?

5

● “unclear how to resolve

differing viewpoints”

● “not familiar with my

teammates”

● “inconsistent goals”

● “unclear objectives

● “who’s in charge”

● “members aren’t open

minded”

● “unclear deadlines”

● “teammates not receptive to

alternative viewpoints”

● “unclear leadership”

● “don’t know who’s doing what

and why”

Common pain points that block team success

Increasing Complexity and Expanding

Geographic Scope of Misconduct

75%

8

9

Bad TeamGood Team

Why do some teams work well

together and others do not?

10

How well team members treat each other

12https://rework.withgoogle.com/

STUDY FINDINGS

Psychological Safety

Dependability

Structure and Clarity

Meaning

Impact

Google Inc. “Understand team effectiveness.” rework.withgoogle.com

Rozovsky, Julia. “The five keys to a successful Google team.” rework.withgoogle.com

PSYCHOLOGICAL

SAFETY

Can we take risks without the

fear of embarrassment or

rejection?

PSYCHOLOGICAL SAFETY

BrainstormAcknowledge

Stress

PSYCHOLOGICAL SAFETY

PSYCHOLOGICAL SAFETY

BrainstormReal-Time

Feedback

Acknowledge

Stress

DEPENDABILITY

Can we count on

each other

individually to do high

quality work on time?

DEPENDABILITY

Alignment of

objectives

Identify and establish

ambitious goals and

track progress towards

them

DEPENDABILITY - OKRs

O bjectives

ey

esults

K

R

DEPENDABILITY - OKR Examples

Objective

Efficient and effective

investigations

Key Result

(1) Average case closure time of less than one month

(2) Assignment of investigation team in 24 hours

(3) Work plan established within 3 days

Enhanced insights into

investigation trends(1) Launch company-wide case management tool by Q2

(2) Publish annual investigations report to Compliance

Steering Committee, Audit Committee, and BoD by

Q3

DEPENDABILITY

Alignment of

objectives

Identify and establish

ambitious goals and

track progress towards

them

Define Priority

and Risk

Create a common

language &

understanding of how

to allocate resources

DEPENDABILITY - Risk & Priority

Priority

Reputational Legal/

Regulatory

Financial Operational

STRUCTURE &

CLARITY

Are our objectives, execution plans,

and roles clearly defined?

Structure & Clarity

01

02

Objectives: What are the goals of each team member on the project?

Execution plan: What is the workstreams that each member responsible

for completing and how does it fit in the overall project?

Roles: Who on the team is responsible for what?03

Structure & Clarity - RACI Matrix

R

A

C

I

Responsible

Accountable

Consulted

Informed

Conducts or executes the

investigation into a particular issue

Directs the investigation and is

accountable for resolution of the issue

Provides key information and

consulted on key decision points

Kept informed of progress and of

the conclusions of the investigation

Structure & Clarity - Hypothetical

➜ Finance director for Middle

East and Africa operations

notices $1 million in unpaid

invoices to a vendor in

Nigeria

➜ Employee who manages

vendor provides

unsatisfactory answer

➜ Finance escalates to you to

investigate

➜ You learn that the employee

has failed to keep track of the

invoices, what they are for and

when they are due

➜ You also learn that the invoices

are for Government- issued

licenses to sell product

➜ Apparently, the published

prices for these Government-

issued licenses are a fraction of

what’s invoiced

▰ Invoice Fraud

▰ Corruption

▰ Performance Management

Structure & Clarity - RACI

Matrix

Structure & Clarity - RACI

Matrix

RACI Table

Ethics &

Compliance

Internal Audit Employee

Relations

Global Security

Corruption Accountable Consulted Out Responsible

Invoice Fraud Informed Accountable &

Responsible

Out Out

Performance

Management

Informed Out Accountable and

Responsible

Out

Structure & Clarity - Workflow

Informed:

Disciplinary

decision by mgm’t

Consulted/Accountable

Review and approve

DRAFT investigation

report

Accountable:

Close loop with

complainant

Accountable:

Respond to

complainant

Accountable: send to

investigating team

Responsible:

Assemble

investigating team

Responsible:

Enter case

into database

Responsible:

Formulate

investigation

plan

Consulted: Consult on

investigation plan

Responsible: Collect & review

applicable docs

Responsible:

Interview

complainant

Responsible:

Interview

witnesses

Responsible:

Prepare DRAFT

investigation report

Accountable:

Communicate

policy changes

Concern

received

Close

Investigation

Responsible:

Analyze data

collected

Responsible:

Interview

subjects

Accountable:

Respond to

complainant

Accountable:

Send to

investigating team

Responsible:

Assemble

investigating team

Responsible:

Enter case in

database

Concern

received

Structure & Clarity - Workflow

Structure & Clarity - Workflow

Responsible:

Formulate

investigation plan

Consulted:

Consult on

investigation plan

Responsible:

Collect & review

applicable docs

Responsible:

Interview

complainant

Structure & Clarity - Workflow

Consulted/Accountable:

Review and approve

DRAFT investigation

report

Responsible:

Interview

witnesses

Responsible:

Prepare DRAFT

investigation report

Responsible:

Analyze data

collected

Responsible:

Interview

subjects

Informed:

Disciplinary decision

by mgm’t & HR

Accountable:

Close loop with

complainant

Accountable:

Communicate

policy changes

if any

Investigation

closed

Structure & Clarity - Workflow

Structure & Clarity - Work

Planning

Topic Task Responsibility Deadline

Were payments made

by vendor directly to

gov’t officials?

Interview vendor

employees

Sarah L. 7/1/2017

Review license pricing Michael S. 6/23/2017

What costs are we

responsible for

reimbursing?

Review vendor

contract

Natalie R. 6/26/2017

Interview vendor

manager

Michelle K. 7/10/2017

Structure & Clarity - Workflow

Management Software

RACI Matrix

Define investigation

responsibilities and

then assign them

Standardize

Process Workflow

Create common

understanding of how

each responsibility fits

within the investigation

workflow

Structure & Clarity - Summary

Work Plan

Identify specific tasks

and create deadlines

within the plan of

execution

Case Management

Track progress

against the work plan

MEANING

Are we working on something

that is personally important to

us?

Meaning - Thoughtful

Assignments

Don’t consider!

- perceived abilities

- perceived workload

- perceived expertise

- perceived experience

Do consider!

- needs of the case

- expressed interest of

team members

- observed strength of

team members

- growth opportunity

for team members

Meaning - Hire the right people

Define the Job!Mission, Role, Responsibilities, Qualifications

Ask good questionsLeadership, ethics, team member empathy

Decisions by committeeHiring by committee, calibrate interviewers

IMPACT

Do our team members believe that

their work matters and creates

change within the organization?

Organizational Justice

1. Employee’s belief that the company doesn’t tolerate unethical

conduct

1. Employee’s belief that the company quickly and appropriately

responds to instances of misconduct

Impact - Perception of Culture

Reduces Risk

CEB, Building Predictive Monitoring Capabilities, Arlington VA, 2015, pg 8.

Impact - Perception of Culture

Reduces Risk

Organizational Justice is a key driver to increasing

employees’ perception of a strong culture of integrity

CEB, Building Predictive Monitoring Capabilities, Arlington VA, 2015, pg 8.

Impact - Upside of Strong Culture

CEB. Integrity Capital Quarterly, Arlington VA, 2016.

Culture Reduces Risk

In a company with a favorable culture,

only 6% of employees observe

misconduct.

And when they see something wrong,

72% of employees will report that.

Impact - Upside of Strong Culture

What do MBAs think about

ethical culture?

97% willing to forgo financial

benefits to work for a company with a

better reputation for ethics and

corporate social responsibility

CEB. “How Culture Reduces Risk (By the Numbers)”, Sept. 11, 2013.

Impact - Downside of Weak

Culture

Impact - Reporting metrics

▰ Reporting metrics is a key element of organizational justice

▰ Reporting to senior leadership can promote change within the organization

ReportRecommen

dAction

CEB, Building Predictive Monitoring Capabilities, Arlington VA, 2015, pg 8.

48

Questions

Q&A

Sources

Duhigg, Charles. “What Google Learned From Its Quest to Build the Perfect Team.” New York Times Magazine. February 26, 2016. Accessed April 10,

2017. https://www.nytimes.com/2016/02/28/magazine/what-google-learned-from-its-quest-to-build-the-perfect-team.html.

Edmondson, Amy. “Psychological Safety and Learning Behavior in Work Teams.” Administrative Science Quarterly Vol. 44, No 2 (June 1999). 354.

doi:10.2307/2666999.

Google Inc. “Understand team effectiveness.” rework.withgoogle.com. Accessed April 10, 2017. https://rework.withgoogle.com/guides/understanding-team-

effectiveness/steps/introduction/.

Matthews, Gail and Pauline Rose Clance. “Treatment of the Imposter Phenomenon in Psychotherapy Clients.” Psychotherapy in Private Practice 3(1), 71-

81. doi:10.1300/J294v03n01_09.

Rozovsky, Julia. “The five keys to a successful Google team.” rework.withgoogle.com. November 17, 2015. Accessed April 10, 2017.

https://rework.withgoogle.com/blog/five-keys-to-a-successful-google-team/.

Tabrizi, Behnam. “75% of Cross-Functional Teams Are Dysfunctional.” HBR.org. June 23, 2015. Accessed April 10, 2017. https://hbr.org/2015/06/75-of-

cross-functional-teams-are-dysfunctional.

Woolley, Anita Williams , et al. “Evidence for a Collective Intelligence Factor in the Performance of Human Groups.” Science Vol 330, Issue 6004 (October

29, 2010). 686. doi: 10.1126/science.1193147

Credits

Special thanks to all the people who made and released these

awesome resources for free:

➜ Presentation template(s) by SlidesCarnival

➜ Photographs by Unsplash

52 of 35 © 2017 Association of Certified Fraud Examiners, Inc.

Building the Perfect Investigations Team to

Find, Eliminate, and Remediate Misconduct

Lisa Chafin

Financial Investigations

Manager, Internal Audit

Google, Inc.

Andrew Price, J.D.

Senior Counsel

Google, Inc.