The Wheatley Institution

Fellow Notes


Competent Fact-gathering is
Critical to Investigating Allegations

“You must find all the pieces to an allegation before making a judgement call.”

Bill O'Rourke | November 13, 2015
| Print | Google plus Google plus linkedin share button
Cogs and Wheels work together like facts that help comprise an allegations investigation in an ethical situation. They are all necessary.



You are responsible for health and safety for your company. Corporate compliance reports it received this anonymous tip on the ethics hotline: “Our plant manager is spinning the safety results at our plant.” What do you do?

It is a mistake to see any ethical issue in terms of economics or liabilities. A cover-up or manipulation of the truth raises an ethical issue that one ignores at personal, professional and organizational peril. In some jurisdictions, the falsification of safety records is a legal violation – although in this instance, the allegation comes from a developing country without strict industrial safety regulations.

Behind the reporting requirement is the fact that sharing of such information with others could prevent a similar incident from occurring elsewhere.

It’s very easy to make an allegation, especially on an anonymous hotline. It’s very important that an investigation be conducted. What did the caller mean by spinning? Maybe the plant manager was getting involved to assure the “right” treatment and medications were being administered – not too much, but enough to properly treat the injured employee. That could be prudent intervention, not suppression.

Choose a person who will investigate in an objective and thoughtful manner

Select a fact-gatherer with character and integrity. If the allegations are true, there could be ramifications, and the fact-gathering process must withstand scrutiny. Choose a person who will investigate in an objective and thoughtful manner. Consider the individual’s education and experience in the area of the investigation.

In this case, one of the best safety professionals with pertinent experience was dispatched to review records and reports, and conduct interviews. Her conclusion verified that 50 incidents had not been reported, 90 percent for relatively minor medical situations. But her interviews verified the plant manager was encouraging victims and the safety manager not to report them.

Usually, each story has two, three or four sides. In this case, the plant manager was performing very well in operations, sales, inventory reduction, quality, and employee engagement. He was being groomed to succeed his boss. He had no prior allegations regarding behavior or performance.

The investigation revealed he knew the corporation’s safety reporting requirements. Six months prior, he attended the two-day, new plant manager training program, which detailed the importance of safety and reporting requirements.

Where does the buck stop? Are there co-conspirators? Answering these questions is part of a thorough investigation. The plant manager’s boss, whose office was thousands of miles away, carried a reputation as a champion for workplace safety. There was no evidence the plant manager was being influenced by his boss to suppress incidents. It appeared the accountability and responsibility rested with the plant manager. Sometimes, this can be a tricky determination. High-level bosses and corporate officers are often driven, charismatic leaders. They push for better and better results, as they should. They are demanding, as they should be. What if the boss was clearly communicating, “I don’t want to see any more safety incidents at this plant?” Does such a statement suggest to subordinates that the truth should not be reported?

Of course not. Authorities must be outspoken and serious in ethical areas. They set the tone of an organization, and that tone must be audible. How often do we hear from leaders “it goes without saying” that work will be conducted with integrity? It doesn’t go without saying, and must be expressed periodically and seriously with words and actions.

Complete fact-gathering will help facilitate a quick decision on the appropriate action

A final step in fact-gathering is to confront the accused party. At this stage, additional facts often are uncovered that might warrant further investigation. In this case, the accused denied the allegation but could not refute the facts. The plant manager said he never instructed his employees not to report safety incident, but admitted he may have over-stressed the importance of a clean safety record.

The results of the investigation should be summarized for presentation and discussion with those in authority to take action. Complete fact-gathering will help facilitate a quick decision on the appropriate action.

* Originally published in the Pittsburgh Business Times on Oct. 4, 2013. Republished with permission.