Who signs the closure memo?

The lead investigator drafts it; the closure panel (typically Head of Compliance plus one other senior officer not in the chain of command of the subject) reviews and signs. For senior-management cases the audit committee chair signs.

Is the closure memo discoverable?

It depends on jurisdiction and whether the investigation was conducted under privilege. Memos prepared by counsel under attorney-client privilege are generally protected; memos prepared by non-lawyer compliance staff are typically discoverable. The privilege analysis is set at the start of the investigation in the investigation plan.

Does the reporter see the closure memo?

No. The reporter receives substantive feedback under Article 9(1)(f) but not the internal closure memo. The feedback message summarises actions taken without disclosing privileged material or the identity of any subject.

Free template · Updated May 2026

Case Closure Memorandum

The closure memorandum is the decision document for a whistleblower investigation. It records the scope, methodology, evidence, factual findings, rule analysis, conclusions per allegation, and the approved remedial actions. It is the artefact the closure panel signs and the artefact most often reviewed by external auditors and regulators.

Cover

Case code	WB-XXXX-YYYY
Date opened	[yyyy-mm-dd]
Date of this memo	[yyyy-mm-dd]
Lead investigator	[Name, role]
Closure panel	[Names, roles]
Privilege status	[Attorney-client privileged / Not privileged]: see investigation plan Step 4
Standard of proof	Balance of probabilities
Category	[harassment / fraud / ABC / safety / accounting / data protection / other]
Severity at intake / at closure	[low/medium/high/critical] / [low/medium/high/critical]

1. Scope

The investigation was opened in response to a report received on [date] alleging [neutral summary of the allegations]. The scope was set out in the Investigation Plan dated [date] and revised on [date]. Out-of-scope matters that arose during the investigation are listed in Annex A.

2. Methodology

The investigation was conducted by [lead investigator and team] under the Investigation Protocol. Evidence was collected and preserved per the Plan. The audit log entry for each material step is linked in the case file.

3. Evidence reviewed

Documents: [n] documents reviewed; key items at Annex B.
System data: [email accounts / system logs / chat / calendar / building access] for the period [start - end], preserved on [date], hashes recorded in Annex C.
Interviews: [n] interviews conducted; memoranda at Annex D. Witnesses interviewed: [n] peripheral, [n] direct, [n] subject (last).
Expert input: [if any: forensic accounting, technical, HR specialist].

4. Factual findings

The investigator made the following factual findings, on the balance of probabilities:

[Finding 1, with evidence references].
[Finding 2, with evidence references].
[Finding 3, with evidence references].

5. Rule analysis

The conduct found is assessed against the following rules:

[Internal policy or code clause].
[Contract clause where relevant].
[Statute or regulation, with citation].

6. Conclusion per allegation

Allegation	Conclusion	Reasoning ref.
[Allegation 1]	Substantiated / Partially substantiated / Unsubstantiated	Findings [n], rule [n]
[Allegation 2]	...	...

7. Residual uncertainties

The investigator notes the following uncertainties that did not affect the conclusion:

[Uncertainty 1].
[Uncertainty 2].

8. Remedial actions approved

Action	Owner	Due
HR consequence for subject [pseudonym]: [warning / final warning / dismissal]	HR Director	[date]
Policy update: [policy] amended to address [gap]	Head of Compliance	[date]
Training: refresher on [topic] for [population]	Head of Learning	[date]
System control: [control] implemented	CIO / CISO	[date]
External referral: [authority] / [no referral]	General Counsel	[date]

9. Communications

Substantive feedback to the reporter: sent on [date] via the case channel using the standard message.
Subject communications: outcome communicated by [HR / line manager] on [date].
Board / audit committee: [briefed on date / not applicable].
Regulator: [briefed on date / not applicable].

10. Retention

Case content is retained per the Retention Schedule for [n years]. The audit log is retained 7 years. Deletion will be executed by the case-management system at [date]; the responsible officer is [Name].

11. Sign-off

Role	Name	Signature	Date
Lead investigator
Closure panel member 1
Closure panel member 2
Audit committee chair (where required)

Annexes

Annex A: out-of-scope matters arising during the investigation.
Annex B: documentary evidence index.
Annex C: preserved-data hashes and chain-of-custody record.
Annex D: interview memoranda.
Annex E: expert reports.
Annex F: investigation plan and revisions.