How Nintendo teams should conduct internal workplace investigations
Practical steps HR and employees can use to run fair, confidential workplace investigations at Nintendo. Learn how to scope, investigate, document, and follow up to reduce legal and reputational risk.

Internal investigations are a workplace baseline: a structured way to respond to complaints, workplace policy breaches, harassment claims, or other employee-relations issues. Treat this as a playbook you can use to level up investigative quality, safeguard confidentiality, and keep the workplace productive while protecting legal and reputational risks.
1. Determine whether an investigation is required
Begin by assessing the complaint against company policies, legal obligations, and immediate safety concerns. Not every complaint requires a full formal investigation; some situations are resolved through coaching, mediation, or an informal remedial conversation. Document the triage decision and rationale so employees understand why a formal investigation was opened or declined.
2. Plan and scope the investigation
Define clear objectives, timelines, and the scope of inquiry: what conduct, period, locations, and people fall within the review. Establish the standard of proof you will apply (for example, preponderance of evidence) and set realistic dates for evidence collection and interviews. A well-scoped plan reduces scope creep and reassures workers that the process is organized and timely.
3. Select an impartial, qualified investigator (internal or external)
Choose an investigator who is neutral, trained in fact-finding, and free of conflicts with parties involved; when necessary, bring in external counsel or third-party investigators. Internal investigators can leverage institutional knowledge but must be demonstrably impartial; external investigators add perceived neutrality and legal experience. Communicate investigator identity and role clearly to participants while protecting sensitive details that could compromise confidentiality.
4. Gather documentary evidence and preserve relevant records
Identify and secure emails, chat logs, personnel files, time records, security footage, and any other documentary evidence promptly to prevent alteration or loss. Use forensically sound methods for preserving electronic data and log chain-of-custody actions so records stand up to scrutiny. Document what you searched for, where materials were stored, and steps taken to preserve them.
5. Conduct timely, well-prepared witness and subject interviews
Prepare a scripted interview plan with open-ended questions, relevant documents, and clear goals for each session; avoid leading or argumentative tones. Interview the subject, complainant, and witnesses separately, give each party an opportunity to respond to allegations, and take contemporaneous notes or recordings in line with local laws and policy. Be mindful of trauma-informed practices for sensitive matters and explain confidentiality limits and next steps before starting each interview.
6. Document findings clearly and objectively
Produce a written report that summarizes facts, evidence, credibility assessments, and whether policies were violated, keeping conclusions grounded in documented evidence. Avoid editorializing; use neutral language and tie conclusions to specific evidence or testimony. Clear documentation supports consistent policy application, informs reasonable remedies, and reduces legal exposure.
7. Recommend appropriate remedial actions or discipline if warranted
Match remedies or discipline to the severity of the misconduct, past discipline records, and the goals of safety and corrective behavior. Remedies can range from training and coaching to reassignments, written warnings, or termination—ensure responses are consistent with company policy and precedent. Explain the rationale for recommendations in the report so decision-makers and affected employees see the connection between findings and outcomes.
8. Follow up to ensure corrective measures are implemented and mitigate retaliation risk
Monitor the workplace after the case closes to confirm remedial actions are in place and effective, and to detect any retaliation or collateral issues. Check in with complainants and relevant supervisors at defined intervals, and document follow-up contacts and outcomes. A credible follow-up process preserves trust, deters repeat problems, and signals that the company enforces its policies.
- Procedural fairness: Apply rules consistently across teams and levels to avoid perception of favoritism. Fair process increases acceptance of outcomes and reduces grievances.
- Confidentiality: Limit information on a need-to-know basis, explain confidentiality limits to participants, and secure investigative records to protect privacy and reputations.
- Consistency of policy application: Use precedents and written discipline matrices where possible to ensure like cases receive like outcomes; inconsistency fuels morale problems and legal claims.
- Careful documentation: Archive reports, interview notes, and evidence logs; a paper trail is essential for audits, grievances, or legal defense.
Additional procedural safeguards that matter
Impact on workers and workplace dynamics A clear, timely investigation calms uncertainty and reduces rumor-driven disruption; it signals that the employer takes concerns seriously. Mishandled investigations create distrust, encourage retaliation, and can chill reporting—while well-run ones protect employees’ rights and preserve team cohesion. For managers, transparent process and fair outcomes reinforce norms; for employees, predictable processes lower the personal risk of coming forward.
Practical closing wisdom Treat investigations like a well-designed game plan: prepare, play fair, record the moves, and follow up on the scoreboard. Consistency, confidentiality, and clear documentation are the simplest ways to protect employees and the company alike. Apply these steps at Nintendo to resolve issues efficiently, maintain trust, and keep the workplace focused on the next level of performance.
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