A whistleblower raised concerns inside the Indian business of a multinational medical-devices company. What began as a contained review grew, in stages and under the direction of the client's US counsel, into an investigation of the company's distributor network, because, in my observation, that is where such allegations usually lead in Indian businesses that sell through distributors.
“The field findings and the sales numbers were used to test each other.”
The work, carried out during my tenure at a global investigations firm, ran in two connected workstreams. The first was systematic: know-your-counterparty reviews and contract analysis across the distributor base, building an evidence file on who these firms were, who stood behind them, and how they transacted. The second was directed: interviews with the whistleblower, investigation of the distributors the allegations pointed at, and cross-referencing of the findings against the company's own sales and growth analytics, so that the field findings and the numbers could test each other.
Each source covers a gap in the others. The whistleblower points to where to look, the distributor records show who the counterparties are, and the sales data shows where the two do not match. In my observation, an investigation that relies on only one of them tends not to survive the next review.