Investigations, Compliance and Ethics

Investigations

The mistake most often made in reviews of this kind is that the process is started in good faith by Human Resources or Internal Audit, but without a legal framework. Evidence later becoming unusable in a job-security action or in an administrative investigation usually originates in the procedural choices of the first day.

• Internal investigations. Planning and managing reviews conducted on a report, an audit finding or a suspicion. Determining the scope and method of the investigation at the outset, collecting digital and physical evidence in a lawful manner, conducting interviews, and reporting the findings in a form that can be used at later stages.
• Regulatory investigations. Representation in examinations conducted by the Competition Authority, the Personal Data Protection Authority, the Capital Markets Board, the Banking Regulation and Supervision Agency, the Ministry of Trade and other authorities; legal support during on-site inspections, responding to requests for information and documents, preparing written defences, representation at oral-defence meetings, and actions for annulment of administrative sanctions.
• On-site inspection readiness. Determining in advance the steps to be followed if an inspection team arrives, briefing the relevant personnel, and preparing for digital data.
• White-collar criminal investigations. Defence in investigations and prosecutions conducted against the company and its managers, conduct of files in which the company is the complainant, and proceedings concerning allegations of abuse of trust, fraud and embezzlement.
• Crisis management. Coordinating the legal and communications steps if an event becomes public, identifying notification obligations and fulfilling them in time.

Compliance and ethics

• Building compliance programmes. Creating practicable programmes designed around the company’s field of activity and its real risks. We prefer to produce rules that actually operate at the point of decision, rather than long policy texts that no one reads.
• Anti-bribery and corruption. Assessing Turkish legislation together with the foreign rules to which the company may be subject, gift and hospitality rules, regulating relations with public officials, and donation and sponsorship policies.
• Whistleblowing mechanisms. Establishing reporting lines, protecting the reporter, assessing incoming reports, and operating this process in line with personal-data legislation.
• Third-party management. Risk assessment of suppliers, distributors, agents and consultants, placing compliance obligations in contracts, and exercising audit rights.
• Prevention of money laundering. Compliance, at obliged entities, with customer due diligence, suspicious-transaction reporting and record-keeping obligations, and the structuring of internal control and the compliance officer.
• Sanctions and export controls. Assessing the effect of international sanctions regimes on the company’s activities, screening of customers and suppliers, controls on dual-use goods, and resolving problems that arise in banking and logistics processes.
• Public procurement. Compliance with procurement legislation, applications against debarment decisions, challenge proceedings, and the application of ethical rules in tender processes.
• Competition-law compliance. Setting the rules for contact with competitors, identifying the sensitive areas in trade-association activity, the limits on sharing price and customer information, compliance in vertical relationships, practical training for employees, and internal-audit work.
• Data-protection and information-security compliance. Auditing the lawfulness of processing activities, managing notification obligations in the event of a breach, and addressing the legal dimension of cybersecurity incidents.
• Sustainability obligations. Compliance work on sustainability reporting and supply-chain due-diligence obligations, and auditing the commitments made in this field.
• Transaction-focused compliance review. Reviewing the target’s compliance history in mergers and acquisitions, reflecting the risks identified in the transaction documents, and planning corrective steps after completion.
• Training. Training programmes, differentiated by level, for the board, senior management and the relevant units, run with examples drawn from the company’s own files.
• Remedial measures. Determining the measures to be taken after an infringement is identified, assessing the options for voluntary disclosure, and using the mechanisms directed at mitigating the sanction.

How we work

Confidentiality and impartiality are essential on internal-investigation files. Where the nature of the file requires it, we separate the team conducting the review from the team that handles the company’s day-to-day advisory work, and we ensure that the findings are shared only with the recipients determined in advance.

Most investigations are short, and time lost cannot be recovered. On the first day of the file we draw up a calendar for items such as the defence period, the notification obligation and the time limit for challenge, and we run every step against that calendar.

You may contact our team about an investigation or a need for a compliance programme.