The classification screen

4 questions before you choose the route.

This page identifies the right question and evidence. It does not determine the legal outcome on a reader’s facts.

01

Who mandated it and how far?

Board, HQ, or HR only.

Mandate
02

Hold issued?

Email, WeChat, laptops.

Hold
03

Counsel-led vs HR-led?

Privilege is thin; still decide.

Lead
04

Regulator already in the building?

Raid page, not this one.

Raid

Working rule: A China internal investigation usually begins with: who instructed it, what is in and out of scope, a document/WeChat hold, whether in-house or external counsel leads, and whether a regulator or prosecutor is already involved.

What changes the answer

The signal ledger.

These facts move the question beyond a label and into a product, money-flow and control analysis.

Signal
Ask the operating question
Why it changes the route
Broader Investigations & Compliance analysis needed
Second related guide.
Do not.
US playbook paste
Upjohn + discovery.
Wrong jurisdiction.
Skip PIPL
Imaging personal phones first.
WeChat page.
Prepare before you escalate

Bring a compact evidence docket—not a pitch deck.

Give a compliance team or counsel the operating facts that reveal the perimeter.

01Allegation memoWhat you think happened.
02System mapEmail, WeChat, ERP.
03Org chartWho to interview.
Common confusions

Questions people ask before they build.

Short answers for orientation. The right result can change with the service model and current rules.

Is this the employment-misconduct page?

No. This is how a compliance investigation starts.

Do we need a PRC law firm?

If criminal or raid risk is real, yes. HQ-only interviews are a common failure.

Primary authorities

Reviewed sources support orientation, not a fact-specific assessment.

PRC Anti-Unfair Competition Law (NPC)
SAMR
Supreme People’s Procuratorate
National laws database (NPC)