Templates by allegation type
Policy & Code of Conduct Investigation Report Template
Last updated 2026-07-30
Rule-based allegations — expense irregularities, timekeeping, misuse of company systems, undisclosed conflicts — look simpler than interpersonal complaints, and in one sense they are: the evidence is usually documentary rather than testimonial. What they turn on instead is notice and consistency.
The two questions that decide most of these matters are whether the employee actually knew the rule, and whether the rule has been enforced against others. A policy that has been widely ignored without consequence is difficult to enforce against one person, and that is a fact the investigation should surface rather than leave for an appeal to discover.
Jurisdiction
Written primarily against US federal standards — EEOC guidance, NLRB decisions and Title VII case law — and against general investigative practice. State law, sector rules (public employers, education, regulated industries) and collective agreements impose additional requirements this page does not cover. Where a page borrows a concept from another jurisdiction it says so explicitly. Outside the US, treat the structure as transferable and the legal references as not.
Policy template
Free Word download, no email required. Or open it in Professional Drafter — it lands in your template library, ready to draft against.
When to use this document
- Expense, timekeeping, procurement or systems-misuse allegations.
- Undisclosed conflicts of interest or outside employment.
- Any allegation where the primary evidence is documentary or system-generated.
Worked example
Fictional scenario. An expense matter: a Regional Manager is alleged to have claimed for meals not incurred. The documents look damning. The interview changes the picture — which is why the documents get put to the employee.
The rule, and which version
Expenses Policy v6, section 3.4: 'Receipts must be submitted for all claims. Where a receipt is unavailable, a manager-approved missing-receipt declaration must be filed within 30 days.'
Effective 1 September 2025. The conduct alleged spans October 2025 – May 2026, so v6 was in force throughout. The employee's signed acknowledgment of v6 is dated 12 September 2025 (item 3).
I checked this before looking at the claims. Measuring conduct against a version that post-dates it is a defect no amount of good fact-finding repairs. Note that v5 required receipts only above £25 — had any of the conduct fallen before September 2025, a different rule would apply to it.
The system evidence, with its limits stated
Expense system export, 1 Oct 2025 – 31 May 2026, extracted by Finance Systems on 14 Jun 2026 (item 5).
- 31 claims totalling £2,140.
- 19 claims, totalling £1,383, carry no receipt.
- No missing-receipt declaration is on file for any of the 19.
Limits of this data, stated alongside it rather than after someone else finds them: the export shows what is attached in the system now, not what was submitted. Finance confirmed that attachments were migrated in January 2026 and that some pre-migration attachments are known to have been lost — they could not say how many or for whom.
What the interview produced
Every one of the 19 claims was put to him individually.
On 11 of them he produced receipts from a personal folder, dated correctly, matching the amounts. He had submitted them by internal post to Finance, which was the practice in his region before the system rolled out and which nobody told him had changed.
On 6 he could not produce a receipt and accepted he should have filed a declaration. He said he did not know the declaration existed. His v6 acknowledgment is signed, so he was on notice of the policy; but the declaration form is not mentioned in the induction deck used in his region (item 9).
On 2 he accepted the claims were wrong — a duplicate submission in March, £47, which he offered to repay and which he had not previously noticed.
Had the documents not been put to him, this report would have recorded 19 unreceipted claims worth £1,383. The accurate figure is 8 claims worth £312, of which 2 are admitted errors.
Consistency of enforcement — and the finding
I asked Finance how the missing-receipt rule has been applied. Of 42 managers in the region, 11 have unreceipted claims on file with no declaration during the same period. No enforcement action has been taken in any case, and Finance was not aware the declaration requirement was being monitored.
That does not excuse a breach. It is directly relevant to whether this employee was genuinely on notice that the rule was live, and it is far better for this report to surface it than for an appeal to.
FINDING: SUBSTANTIATED IN PART. 8 claims totalling £312 were submitted without a receipt and without the required declaration, in breach of section 3.4. The £47 duplicate was an error, not a deliberate claim — section 3.4 is a strict requirement and does not require intent, so it is breached either way, but I record that I found no evidence of deliberate false claiming.
NOT SUBSTANTIATED: the allegation as originally framed, that claims were made for meals not incurred. The evidence does not support it.
Section-by-section guide
What each section is for, what a good one contains, and where they typically go wrong.
1.Matter identifiers
Parties, dates and who commissioned the investigation.
2.Scope and standard of proof
What you were asked to determine, what is expressly excluded, and the standard applied — ordinarily the preponderance of the evidence.
3.The rule relied on
Quote the provision verbatim with its version and effective date, and confirm it was in force when the conduct occurred. Applying a policy version that post-dates the conduct is a defect no amount of evidence repairs.
4.Notice — did the employee know the rule?
Evidence they were on notice: acknowledgment records, training completion, induction materials, prior reminders. Where the rule is not intuitive, notice does real work — and its absence is often decisive.
5.Documentary and system evidence
Set out the records with their provenance: what system generated them, over what period, and who extracted them. System data feels objective and frequently is not — access logs record badge use rather than people, and expense systems record submissions rather than intent.
6.The employee's explanation
Put every document to them and record the response to each. Rule-based matters are where investigators most often skip this, because the documents seem to speak for themselves. They rarely do — there is often an approval, a practice or an instruction that changes the picture entirely.
7.Consistency of enforcement
How the rule has been applied to others. If it has been routinely breached without consequence, that is directly relevant and should appear in the report rather than emerging later at appeal.
8.Intent, where the rule requires it
Some provisions require deliberate conduct; others are strict. Read the provision carefully and state which it is, because the evidence needed differs substantially between them.
9.Evidence summary and credibility
This is the one allegation type where the record usually outweighs the testimony. Lead with the system data and the paperwork, state their limits alongside them, and use the accounts to explain the record rather than to establish it.
10.Findings of fact
One finding per numbered allegation: substantiated, not substantiated, or inconclusive, with the evidence relied on.
11.Policy analysis
Apply the facts found to the policy provisions quoted, keeping the two questions separate.
12.Investigator statement and appendices
Attestation of impartiality, the limits of the report, signature, and a numbered appendix index.
Common mistakes
The failure modes that show up most often when this document is reviewed later.
Applying the current policy version to older conduct
Conduct is measured against the rule in force at the time. Using a later version is a defect that survives any amount of good fact-finding.
Not putting the documents to the employee
Documents rarely speak for themselves. Approvals, informal practice and direct instructions routinely change the meaning of a record.
Ignoring inconsistent enforcement
A widely tolerated breach is hard to enforce against one person, and it is far better for the report to surface it than for an appeal to.
Treating system data as self-evidently reliable
Badge logs record credentials, not people. State the limits of the data alongside the data.
Questions
- The employee says everyone does it. Does that matter?
- Yes, and you should find out whether it is true rather than dismissing it. Inconsistent enforcement goes to whether this employee was genuinely on notice that the rule was live, and selective enforcement can be a problem in its own right. Record what you found either way — it is far better for the report to surface it than for an appeal to.
- The system data looks conclusive. Do I still need to interview them?
- Yes. Documents rarely speak for themselves in these matters: approvals, informal regional practice, migration failures and direct instructions from a manager routinely change what a record means. Putting every document to the employee is also the step whose absence makes a finding hardest to defend.
- Do we need to prove intent in a policy breach investigation?
- Only if the provision requires it. Read the wording: some rules are strict, others require deliberate or knowing conduct. State which standard applies before assembling the evidence.
- What if the policy has been widely ignored?
- It is directly relevant and belongs in the report. Inconsistent enforcement affects whether the employee was genuinely on notice and whether selective enforcement is itself a problem. Record it rather than leaving it to surface at appeal.
The blank template
Exactly what is in the Word download, so you can see the structure before deciding whether you want it.
Matter identifiers
Scope and standard of proof
The rule relied on
Notice — did the employee know the rule?
Documentary and system evidence
The employee's explanation
Consistency of enforcement
Intent, where the rule requires it
Evidence summary and credibility
Findings of fact
Policy analysis
Investigator statement and appendices
Download this template
Free Word download, no email required. Or open it in Professional Drafter — it lands in your template library, ready to draft against.
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Findings of Fact Template: Substantiated, Not Substantiated, Inconclusive
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This page is a documentation aid, not legal advice. Workplace investigation requirements vary by jurisdiction, sector and policy, and a template cannot tell you what your matter requires. The worked example describes a fictional scenario.