There are few things an association executive dreads more than the prospect of an internal investigation. Accusations of workplace bias, embezzlement, misbehavior—it all spells expense, frustration, reputational harm, and disappointment.

So perhaps it’s common sense that a leader’s shrewdest move is to get ahead of the problem. Earlier this month, Holly E. Peterson, counsel at Tenenbaum Law Group, which represents associations, wrote an article offering tips about how associations can handle investigations. In an interview, she notes that associations do best when they create an environment where an investigation doesn’t come to pass. 

“A lot of times what I see in these matters is that it starts with something relatively minor that percolates over time and becomes something that is no longer minor,” she says. “It could sometimes start with an interpersonal conflict between employees that’s never addressed. It’s not addressed from the managerial or an HR perspective, in that early moment. And then it builds and builds and builds, and all of a sudden something takes place that turns it into a much bigger matter than it ever once was.”

If matters have escalated to the point where an investigation is necessary, though, there are a variety of factors to consider. Below are just three of some top-level issues leaders should think about as they take that uncomfortable but crucial step.

Shore up your code of conduct. Associations are especially vulnerable at the big conference’s boozy mixers, Peterson says. “One that we encounter a lot, unfortunately, is at live annual conferences after the bar is open. Bad things happen from time to time, sometimes with employees, sometimes with members, sometimes with board members. That’s that’s really a ripe area for misconduct to take place and for associations to have some sort of obligation, depending on the circumstances, to follow up.”

The association’s code of conduct is the key document in such cases. Peterson lists some questions to ask and points to consider:

• Who does it apply to? All registrants? Volunteers? Vendors? Exhibitors? Who else?
• What behavior is prohibited? It should be specific enough to put people on notice of expectations but not so specific that it prevents the organization from swiftly addressing an unforeseen matter.
• How do attendees report violations? To whom? Do you have a dual reporting structure?
• What process will be followed? Here, you want to give the organization the broadest amount of discretion possible.
• What are potential sanctions for conduct infractions?

Internal or external? With some conflicts, having the association’s CEO and/or HR chief lead an investigation makes sense. But in cases where a large number of people are involved, hot tempers, conflicts of interest, and questions about where the bylaws, code of conduct, and even the law apply, it may be more sensible to bring in an outsider. That might be a lawyer, or a trained workplace investigator. But discuss what makes the most sense, Peterson says.

“The first thing that you need to do is figure out who the players are,” she says. “Are we talking about two entry level employees? Are we talking about your chief executive officer? Are we talking about someone on the board? You need to figure out who’s part of this, because whether you’re going to choose to investigate in house, or whether you’re going to move it to an external party.”

The goal is fairness, not happiness. It’s a natural instinct to want a resolution that pleases everybody, but in cases that rise to the level of an investigation, that may not be likely. Leaders should focus on responses that are as transparent as possible and fact-focused. “A good outcome, from my perspective, is one where you have a neutral and fair and unbiased process put in place, and at the end that if I were to ask for each finding of fact, ‘On what did you base that?’ that there would be an answer to that question.”