Situation
Received a whistleblower complaint?
Treat every credible complaint as a potential investigation: preserve evidence, protect the whistleblower and appoint an independent team. We investigate the allegation discreetly and give your audit committee a factual, evidence-backed report it can act on.
Warning signs
Signs you need an independent investigation
- An anonymous or named complaint alleging fraud, bribery, harassment or policy breaches
- Allegations that involve senior management or the promoter group
- A complaint received through your vigil mechanism or ethics helpline
- Concerns raised by an auditor, regulator or business partner
- Repeat complaints about the same function, vendor or individual
Act quickly, act carefully
What to do in the first 48 hours
- Step 01
Acknowledge and protect
Acknowledge receipt, keep the whistleblower’s identity confidential and make it clear that retaliation will not be tolerated.
- Step 02
Preserve evidence
Secure emails, devices, ledgers and access logs before anyone connected to the allegation is alerted.
- Step 03
Limit the circle
Restrict knowledge of the complaint to those who need it; route oversight to the audit committee where management may be conflicted.
- Step 04
Appoint independent investigators
Independence makes the findings credible to the board, auditors and, if needed, regulators and courts.
Our approach
How we investigate
- 01
Assess and scope
Evaluate the allegation, identify the questions to answer and agree a proportionate investigation plan.
- 02
Collect evidence forensically
Image devices and email accounts, extract accounting data and document a defensible chain of custody.
- 03
Analyse and corroborate
Forensic accounting, data analytics and background research test the allegation against the facts.
- 04
Interview
Structured interviews with relevant employees and, where appropriate, the subject of the allegation.
- 05
Report and remediate
A clear report of findings for the audit committee, with recommendations on controls and next steps.
What you receive
- Investigation report for the audit committee or board
- Evidence file with documented chain of custody
- Root-cause analysis and control recommendations
- Support for disciplinary, legal or regulatory follow-up
Frequently asked questions
Is a company in India required to have a whistleblower mechanism?
Yes for many companies. Section 177 of the Companies Act, 2013 requires every listed company and certain other classes of companies to establish a vigil mechanism for directors and employees to report genuine concerns, and SEBI’s LODR Regulations require listed entities to formulate a vigil mechanism or whistleblower policy.
Who should oversee a whistleblower investigation?
Ideally a body independent of the people implicated (usually the audit committee or a committee of independent directors), working with an external investigation team so the findings are credible and free of conflicts.
Should we investigate anonymous complaints?
Anonymous complaints should be assessed on their substance. If the allegation is specific and plausible, a preliminary review is prudent; many significant frauds first surface through anonymous tips.
Proof
Relevant case files
Clearedleadership, on fraud and favouritism
The Budget That Wasn't Blown
An anonymous letter accused a school's leadership of a fivefold budget overrun and favouritism. The facts cleared them and surfaced a different risk.
- Spend reconstruction
- Independent price discovery
- Vendor integrity assessment
- Recruitment and pay review
₹1+ Crbad-debt exposure quantified
The Customer That Didn't Exist Yet
A logistics company signed a credit contract with a customer a week before it was incorporated, and paid the customer's sister company to move goods that may never have moved.
- Document and transaction review
- Corporate and tax records
- Transaction analytics
- Personal financial review
Client names and identifying details are withheld to protect confidentiality. Specific references and client experiences can be shared on request, with the client’s consent.
Other situations
Facing something different?
- Suspect fraud, embezzlement or financial misconduct?Establish what happened, who was involved and how much was lost, with evidence that stands up.
- Suspect vendor kickbacks or procurement fraud?Find collusion, kickbacks, inflated invoices and fictitious vendors in your purchasing and supply chain.
- Vetting a partner, vendor or acquisition target?Know who you are dealing with before you sign, invest or onboard: promoters, related parties and reputation.
- Need to trace hidden or diverted assets?Find assets that have been concealed, moved or held through others, and support their recovery.
- Facing a dispute that needs forensic evidence?Quantify losses, analyse the evidence and give expert opinion that stands up in court or arbitration.
- Digital evidence at risk, or data leaked?Preserve, recover and analyse emails, devices and cloud data so the evidence holds up when it is challenged.