On March 6, 2014, the U.S. District Court for the District of Columbia ruled that documents related to internal investigations of possible violations of corporate codes of conduct are not protected from disclosure under either the attorney-client privilege or attorney work product doctrine. The court instead concluded that the company's investigations were conducted pursuant to "regulatory law and corporate policy," rather than for the purpose of obtaining legal advice. As discussed in a recent Reed Smith client alert, the ruling serves as timely reminder for health care companies to review internal procedures relating to internal corporate compliance program or code of conduct investigations to maximize the likelihood that appropriate privileges will be honored. For details and analysis, read the full Reed Smith alert.
This article is presented for informational purposes only and is not intended to constitute legal advice.