Jeffrey M. Kaplan (jkaplan@kaplanwalker.com) is a Partner with Kaplan & Walker LLP in Princeton, New Jersey, USA.

In establishing an internal investigation regime to address compliance and ethics violations, a private sector entity need not meet full constitutional due process standards. But there are still many reasons to implement an investigations manual, including assuring that investigations are thorough, fair, confidential, legally sound, well documented, and otherwise fit for purpose.

What specifically should be included in such a document? Among other things, it should set forth or otherwise discuss: