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368 An HR Guide to Workplace Fraud and Criminal Behaviour

    You should plan the first step, as you would for any other investigation. This would nor-
mally involve interviewing the subject and, assuming he has been identified with reasonable
certainty, the informant.

Interviewing the subject

Your approach to the subject will depend on the strength of the evidence and the fraud theory
but in most cases it should be based either on blocking questions (see page 198), or on a low-key
opening statement and then conducted along the lines laid down in Chapter 7. If his reaction
tells you the allegations are likely to be true, you must press on to try to find the deep truth.

    The greatest difficulties arise when you are not sure, one way or the other, about the ac-
curacy of an allegation. In these cases, it is usually best to explain the allegations in detail and
to ask the subject to cooperate fully, by making bank and other records available and to work
with you to disprove them and to help you identify the informant.

    Innocent people usually fight to clear their names

Interviewing the informant

In many cases, the identity of the informant will become obvious and you should always try
to interview him. Again your approach must be carefully planned and will depend on:

• the degree of certainty that he is the informant;
• the credibility of the information provided;
• his apparent motivation.

If you merely suspect that a person is the informant, you should still interview him but in a
very circumspect way, using open questions about the area in which the subject works. You
should not mention the subject’s name unless he raises it first, nor should you show him the
anonymous letter. If the person appears cooperative you may then move on to discussing the
specifics of the allegation, but again avoiding the subject’s name: his reaction should tell you
whether or not he is the informant.

    If you are reasonably certain that you have identified the informant you may take a more
direct approach, but you must be careful not to put words in his mouth or slander the subject.
Again your approach should be adapted to suit the circumstances. For example, if the infor-
mation appears correct and the informant not motivated by malice you might take a low-key,
empathetic approach from the outset, whereas if the allegations are false, you may treat the
informant as a suspect and interview him accordingly with the objective of exposing and, in
due course, punishing him.

    In any event you should probe the information in depth, looking for supporting evidence
and exploring other matters. If it emerges that the allegation is false and the informant is
motivated by malice, consider obtaining a retraction in writing.

Follow-up action

It is imperative that allegations are not left on the subject’s personnel file unresolved, and in
all cases a report on the investigation should be prepared. Other closure action is essential and
can be determined on the matrix below (Table 9.5).
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