The landscape of compliance investigations: Integrity Investigations

Integrity investigations form a substantial part of compliance-related inquiries. They do not focus solely on financial fraud but cover a broad range of issues: conflicts of interest, abuse of position, ancillary activities (side business or job), and violations of codes of conduct. While a fraud investigation often revolves around hard numbers and financial trails, integrity issues are usually more subtle. They concern human relationships, motives, and grey areas where rules and ethics intersect.

Integrity is the foundation of trust within organizations. Yet integrity risks often go unnoticed, with far-reaching consequences for reputation, compliance, and business continuity. In this third article in our series, the focus is not on investigative techniques, but on what integrity investigations mean in practice: which themes recur, and which patterns emerge from recent cases. We discuss not only well-known integrity risks, but also the less obvious threats.

We begin with a brief overview of the trends that shaped integrity investigations in 2025. We also briefly highlight the differences between integrity investigations and fraud investigations, discussed in the previous article. We then turn to practice: which cases recur, and how can signals be recognized? By doing so, we also shed light on several underexposed indicators.

Trends in Integrity Investigations

Integrity issues are shifting from a narrow focus on corruption and fraud toward broader domains such as conflicts of interest, reputational risk, and moral dilemmas. Recent developments show that:

Conflicts of interest and their appearance are increasingly being reported, often in relation to ancillary activities, procurement processes, or decision-making where personal relationships play a role.
Codes of conduct for board members, supervisory board members, and political officeholders are being tightened, with a strong emphasis on transparency regarding secondary interests and cooling-off periods.
Supervisory authorities such as the AFM and DNB require reliability assessments for board members and supervisory board members, with explicit attention to integrity-related antecedents.

These trends make integrity investigations more relevant than ever. They are not only reactive but also play a preventive role in promoting sound governance and an ethical organizational culture. Later in this article, we will see one of these trends reflected in a case example.

What Makes Integrity Investigations Different from Fraud Investigations

Compared to the forensic fraud investigation discussed in our second article, integrity investigations differ in several important ways:

Greater normative discussion: While fraud investigations often focus on the question “Is there financial damage, and who is responsible?”, integrity investigations more frequently revolve around norm-setting: what could reasonably be expected of someone, which behavioral standards apply, and how heavily the appearance of impropriety and reputational risk should be weighed?
Fewer hard figures, more context: Relationships, organizational culture, and power dynamics play a much larger role in integrity cases. A single email or expense claim rarely tells the whole story; only when combined with statements, behavioral patterns, and internal policies, a coherent picture emerges.
Greater sensitivity regarding privacy and reputation: Investigations often involve individuals in visible or senior positions. This makes careful handling of personal data, communication, and the principle of hearing both sides particularly important.

It is precisely this mix that makes integrity investigations both challenging and valuable for boards, HR, and compliance: they force organizations to articulate their values in concrete terms.

Integrity Investigations: When Behavior Is Under the Microscope

Where fraud investigations often focus on falsified documents, financial loss, and potential criminal elements, integrity investigations mostly operate in grey areas. They address questions such as which interests are at play, which norms apply, and what can reasonably be expected of a professional or manager?

In practice, reports of potential conflicts of interest, ancillary activities, inappropriate conduct, and breaches of codes of conduct have been increasing for years, in both public and private organizations. To make this more tangible, we present a case example below.

“You Don’t Want to Create an Uncomfortable Work Atmosphere, Do You?”

A large family-owned logistics company is known for its reliability and customer focus. This sense of stability is disrupted when an anonymous report is submitted to the compliance officer. An employee in the procurement department is suspected to regularly accept expensive gifts from a supplier, ranging from lavish dinners to tickets for exclusive events. In isolation, this might seem harmless, except for the fact that this employee is responsible for awarding transport contracts.

Further investigation reveals that the employee also holds a secondary position at a start-up operating in the same market. This start-up appears to be using competitively sensitive data, possibly obtained through informal conversations with the employee.

But that is not all. Deeper investigation shows that the employee not only accepted gifts, but also subtly pressured colleagues to be “realistic” when reporting performance figures. Minor adjustments to reports, just enough to meet bonus targets. Colleagues had noticed signals but remained silent: “it wasn’t their department” and “you don’t want to create an uncomfortable work atmosphere.”

What began as a simple report about gifts quickly unfolds into a web of conflicts of interest, a culture of looking the other way, and subtle data manipulation to justify performance bonuses.

This case is not an exception. It illustrates precisely the trends mentioned earlier and shows how integrity risks often do not present themselves as such but grow gradually within the daily routines of organizations. It also demonstrates how different risks, such as conflicts of interest, ancillary activities, group pressure, and data manipulation, can become intertwined.

In investigations of such situations, decision-making processes around procurement, documentation of bids and award decisions, email or calendar records, and publicly available information on ancillary activities are examined. These sources are analyzed collectively to answer three core questions:

Were there personal or business interests that could have influenced decisions?
Were these interests disclosed or made transparent, for example through a gift, activity register or integrity declaration?
Were decisions demonstrably different from what could reasonably have been expected, given price, quality, and internal policy?

Outcomes are rarely black and white. Sometimes investigations show that no formal rules were violated, yet an appearance of a conflict of interest emerged, calling for clearer agreements to roles. In other cases, policies were deliberately circumvented or information withheld, making the violation of norms more explicit.

Practical Indicators from Integrity Investigations

Beyond the above case, other recurring types of integrity issues frequently arise in investigations. Some of the usual suspects include:

A Culture of “Don’t Ask, Don’t Tell”: Perhaps the most damaging risk is a culture in which employees prefer to look away rather than ask questions. Many employees still hesitate to speak up for fear of repercussions or because they do not want to be seen as “complaining”. A typical example: an employee notices signals of misconduct but remains silent because “it’s not my department”.
Data Manipulation: The Silent Saboteur: In the pursuit of targets and bonuses, there can be a strong temptation to present figures slightly more favorably than they are. At a financial institution in Rotterdam, a team leader was found to have adjusted customer satisfaction scores for months. “Everyone does it,” was his defense. The consequences, however, were significant: customer and supervisory trust eroded, and the organization was forced into a costly remediation process. With the rise of AI tools performing data analyses, this risk is only increasing. Who controls the controller?
Conduct and Power Dynamics: Reports of inappropriate behavior, offensive remarks, or pressure from managers also fall under the scope of integrity, even if there is no financial component. These cases concern social safety, use of power, and whether behavior aligns with codes of conduct and professional standards. Investigations focus primarily on patterns: is the behavior incidental, or has it been known for years?
Handling Confidential Information: A former employee is accused of taking confidential documents to a new employer. Key questions include whether confidentiality agreements were breached, whether files were copied without authorization, and whether sensitive information has surfaced where it should not be. Legal, technical, and behavioral issues intersect in such cases.

These examples show that integrity investigations are not merely about “rules”. They are about trust, role modelling, and the credibility of commitments to integrity. Next to these more generally known integrity issues, we would like to address some underestimated issues.

Underestimated Risks: What You Don’t See, but May Still Encounter

Some less obvious, yet in our view highly relevant, risks deserve attention:

Loyalty Conflicts: A growing phenomenon involves employees who run side businesses, perform consultancy work, or even hold secondary jobs with competitors. This is not inherently wrong, but it becomes risky when confidential information or conflicting interests are involved. Consider the IT employee who develops an app in their spare time using data from their primary job, or the procurement officer who also “coincidentally” works for a competitor. Organizations often fail to adequately monitor this, despite potentially severe consequences ranging from data breaches to legal claims.
Group Pressure and Groupthink: Decisions are (often) made collectively, but what happens when critical voices are ignored? At a tech start-up in Amsterdam, pressure to scale rapidly led to ethical objections against a new data sales strategy being dismissed. The result was a breach of the GDPR, and a fine imposed by the Dutch Data Protection Authority. Group pressure can lead to tunnel vision, where alternatives and risks are no longer considered. A simple but effective solution? Explicitly appoint a “devil’s advocate” during meetings to challenge assumptions.
Greenwashing: The Pitfall of Social Claims: Sustainability and corporate responsibility are high on the agenda. But what if reality falls short of promises? A clothing brand claiming to be “100% circular,” while in reality using only 10% recycled materials, risks not only reputational damage but also legal action. External verification of sustainability reporting is no longer a luxury, but a necessity.

These examples show that integrity risks are not always visible, yet they have real impact. They often arise in grey areas where rules and ethics intersect. The danger is that organizations focus on well-known risks, while the true threats play out in everyday practice, informal agreements, unspoken expectations, and well-intentioned but poorly considered decisions.

The good news? By consciously addressing these underestimated risks, and by fostering a culture in which employees feel safe to ask questions, many problems can be prevented. Open dialogue, regular risk assessments, and clear agreements regarding ancillary activities, decision-making, and communication are essential. Integrity is not a matter of luck, but of awareness and action. The earlier risks are recognized, the better they can be managed before they escalate.

Growing Attention to Integrity

Recent reports and governance codes encountered in our work show that integrity is increasingly linked to concrete standards, assessments, and practical guidance. Examples include:

Tightened codes of conduct for board members and supervisory board members, with emphasis on transparent disclosure of secondary positions and interests;
Local and sector-specific codes of conduct (for example in municipalities, education, and housing corporations) that explicitly define how to deal with gifts, ancillary activities, and decision-making in situations of doubt;
Clear guidelines for safe reporting procedures (whistleblowing) and independent handling, ensuring that reporters feel protected and that investigations are conducted independently of operational management.

Integrity investigations directly support these frameworks: they are the instruments used to assess whether these standards are genuinely upheld in practice.

Invitation to Consultation

We can imagine that, after reading this article, you may have questions or wish to exchange views on certain topics. Or perhaps you are dealing with a concrete case and would like to discuss it. We invite you to contact us without obligation for an introductory conversation about you and/or your case. Our contact details can be found at the end of this article or on our website.

Looking Ahead to the Fourth Article

The risks discussed, ranging from loyalty conflicts to group pressure, often remain hidden until someone has the courage to report them. In the fourth article of our series, we therefore take a deeper dive into whistleblowing investigations: how should organizations handle internal (or external) reports? How can employees be encouraged to speak up? And how can a report and the investigation results be translated into genuine, lasting change?

Get in touch

Dennis van der Meer | +31618948848 | dennis.van.der.meer@compliancechamps.com

Boy Custers | +31649935735 | boy.custers@compliancechamps.com

The Landscape of Compliance Investigations: Integrity Investigations