Extract to table

The investigation must be conducted by qualified personnel, must be impartial, and must result in appropriate remedial action where allegations are substantiated

Cross-Border Privilege Considerations Because AGMG is incorporated in England and Wales and is listed on the London Stock Exchange, while the investigation concerns conduct that occurred primarily in the United States, privilege must be maintained under both US and UK law

The treatment of legal professional privilege in England and Wales differs in certain respects from the attorney-client privilege under US law, and care must be taken to ensure that the investigation's privilege protections are preserved in both jurisdictions