Whistleblowing Investigation Report

Overview

Structure and safeguard investigation reports so they are fit for board or regulator sharing: protect whistleblower anonymity (EU Whistleblowing Directive) and correctly mark legal-advice content as privileged (SOX / audit committee context). The skill guides drafting, then running two checks before distribution — anonymity redactor and legal privilege tagger.

Example Chat

You: We’ve finished the internal investigation into the procurement complaint. Draft an investigation report from the materials in interview-notes/ and evidence-summary.md. We need to share it with the audit committee next week — run the anonymity check and fix any issues before we send it.

Agent: I’ll draft the report using the standard structure (executive summary, scope, methodology, findings, conclusions, recommendations) and keep phrasing neutral so we don’t attribute statements directly to the reporting person. I’ll create investigation-report.md and then run both validation tools.

Agent: Draft is in investigation-report.md. Running anonymity_redactor on it now…

Agent: Here are the results of anonymity_redactor on investigation-report.md:

— WARNINGS (review before board sharing) — Line 34: Direct attribution to reporter — “The whistleblower stated that the contract was awarded without a tender.” Line 41: Role or title that may identify reporter — “Head of Procurement” Line 58: Date tied to report — “reported on 12 March 2024”

I’ll revise those now: I’ll change line 34 to “It was reported that the contract was awarded without a tender,” remove the specific role at 41 and refer to “the relevant department,” and generalise the date at 58 to “during Q1 2024.” Then I’ll run the legal privilege tagger.

Agent: Revisions applied. Running legal_privilege_tagger…

Agent: legal_privilege_tagger found one section with legal counsel content (the “Legal assessment” section). It’s already marked “Privileged & Confidential” at the top — no change needed. Summary:

— SECTION STATUS — [OK] Lines 89–102: “Legal assessment” -> Legal counsel advice

The report is ready for audit committee distribution. I’ve left a short note at the top of the file reminding readers that the Legal assessment section is privileged and should not be forwarded outside the committee without legal approval.

Output Excerpt

After the agent drafts and runs both tools, a typical report looks like this. The executive summary and findings use neutral phrasing and no reporter identifiers; the legal section is clearly marked.

# Internal Investigation Report — Procurement Complaint
Ref: INV-2024-03 | Confidential

## 1. Executive summary

The investigation examined allegations regarding the award of a services contract in Q1 2024. It was reported that the contract was awarded without a competitive tender and that certain documentation was incomplete. The investigation reviewed procurement files, internal communications, and relevant policies. Findings are set out below; conclusions and recommendations follow. The relevant department has been reminded of the mandatory tender threshold and document retention requirements.

## 2. Scope and methodology

Scope: Allegations relating to Contract Ref. XYZ-2024-01, award process, and associated documentation. Period: January–March 2024. Methodology: document review, internal interviews (conducted under confidentiality), and cross-check with procurement and finance records.

## 3. Findings

- **Award process:** The contract was awarded without a formal tender. Internal policy requires tenders above €50k; the contract value was €72k. No waiver was documented.
- **Documentation:** The contract file did not contain a written justification for single-source award or minutes of the decision. It was reported that verbal approval was given by a member of the leadership team; this could not be independently verified from the file.
- **Timeline:** The award was made in Q1 2024. Follow-up actions by the relevant department have been documented separately.

## 4. Conclusions and recommendations

Conclusions: The award did not comply with internal procurement policy. Documentation was insufficient. Recommendations: (1) Issue a written reminder to all budget holders on tender thresholds and waiver documentation. (2) Ensure contract files are complete before sign-off. (3) No further disciplinary action recommended on the basis of this investigation; the matter is closed subject to the above.

## 5. Legal assessment

**Privileged & Confidential — Attorney-Client Communication. Do not distribute without approval of Legal.**

In-house counsel advised that the facts as documented do not, in their view, give rise to regulatory reporting obligations in the jurisdictions concerned. Counsel further advised that the audit committee may rely on this investigation report for the purpose of oversight; any external disclosure should be coordinated with Legal.

The anonymity redactor would report no remaining warnings on this text; the legal privilege tagger would confirm that the Legal assessment section is correctly marked.

Extension Tools

The skill includes two validation tools; run both before distributing the report to the board or audit committee.

anonymity_redactor scans the report for accidental identifiers of the whistleblower:

• Direct attributions — e.g. “the whistleblower stated,” “according to the reporter,” “the reporting person said”
• Roles or titles — job titles or department names that could identify a single person (e.g. “Head of Procurement,” “HR Manager”)
• Name-like phrases — sequences of capitalized words that may be names (reported as INFO for manual verification)
• Dates or locations tied to the report — e.g. “reported on 12 March,” “disclosed at the London office”

The tool returns a line-by-line report (WARNING / INFO). Address warnings by redacting or generalising (e.g. “it was reported that…”, “the relevant department,” “during Q1 2024”).

legal_privilege_tagger ensures sections containing legal counsel advice are correctly marked:

• Detection — sections that refer to legal advice, attorney–client privilege, work product, in-house or outside counsel, privileged communications, or content prepared at the request of counsel
• Marking check — each such section must contain a “Privileged & Confidential” (or equivalent) marking in the section header or opening paragraph
• Report — lists sections with legal content and whether they have the required marking; flags any section with legal content but missing marking as ERROR

Add the marking to any flagged section before finalising the report for distribution.

Getting Started

Add your source materials (interview notes, evidence summaries) to the project workspace and activate the Whistleblowing Investigation Report skill. Draft the report, then run both tools in sequence before distribution.