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Internal investigation · illustrative case, with fictional data

Maintenance procurement at a mid-size manufacturer

A report to the ethics hotline pointed to favoritism toward a supplier. The board commissioned a review of 24 months of purchasing before deciding whether to open a formal investigation.

Origin
Report to the ethics hotline
Scope
Purchasing, supplier registration and payments
Period
24 months
Criteria
Purchasing Policy, authority matrix and Code of Conduct

How the work unfolded.

  1. Engagement

    Sponsored by the board. Requests made through the audit committee, bypassing the purchasing team.

  2. Document review

    3,215 documents cataloged and triaged. 41 gaps identified.

  3. Second round of requests

    36 gaps filled. 5 remain open and are disclosed in the report.

  4. Reading and cross-checking

    All documents read and cross-checked against one another. 12 findings verified against the source.

  5. Delivery

    A report with next steps and a walkthrough meeting with the committee.

Critical findings.

The other 9 (5 high, 4 medium) are in the full report.

G-03 Critical

Supplier's bank details changed three days before the largest payment

[Supplier A]'s bank details were changed on 9 August without the required second validation. On 12 August the supplier received the largest payment of the period.

Documents cross-referenced
  • DOC-0877 · p. 2
  • DOC-0912 · p. 1
Criterion
Purchasing Policy, item 6.1: changes to bank details require dual validation.
G-05 Critical

Competing quotes with identical layouts and the same typo

The three quotes come from different suppliers, but repeat the same formatting and the same error in the item description (“preventive maintanance”).

Documents cross-referenced
  • DOC-1104 · p. 1
  • DOC-1105 · p. 1
  • DOC-1106 · p. 1
Criterion
Purchasing Policy, item 3.4: at least three independent quotes.
G-09 Critical

Nine service orders paid with no evidence of execution

None of the nine orders has a technical report, a gate log or sign-off from the requester. All were paid in full.

Documents cross-referenced
  • DOC-1530 to 1538
  • DOC-2201 · no entries
Criterion
Purchasing Policy, item 7.2: payment conditional on acceptance of the service.

Disclosed gaps

What couldn't be read, and why. No finding depends on these documents.

  • Framework contracts for two suppliers, not located
  • ERP log older than the last 18 months
  • Purchasing team emails, outside the authorized scope
  • Three months of invoices in PDF only, without XML
  • Gate log for one of the warehouses

Recommended next steps

Action Findings
Preventive block on payments to [Supplier A] G-03, G-07
Formal inquiry, with interviews of those involved G-03, G-05, G-07
Recovery of amounts paid without acceptance G-09
Review of segregation of duties in the ERP G-07

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