A Complaint Against Your Armenian Country Manager: Who Should Investigate, and How?

When the complaint is about the person who runs your Armenian office, the investigation should be commissioned by HQ or the board and carried out by someone outside the manager’s reporting line, and any sanction must follow within one month of the employer discovering the misconduct. Armenian law sets that clock and the dismissal rules; it says almost nothing about who investigates, so the choices on independence, evidence and language are yours to make and to defend later in court.

Why a complaint against senior local management is different

In most Armenian subsidiaries the country manager hires local HR, approves expenses, holds the administrator rights to local systems and signs for the company. A complaint routed through the normal local channel therefore lands on the desk of the person accused, or on the desk of someone who reports to them. The first decision HQ has to take is to move the complaint out of that line.

Check what the manager actually is in corporate terms. If they are the director of the Armenian LLC (its executive body under the charter and the state register), removing them from that office is a corporate decision governed by the Civil Code and the law on limited liability companies, separate from ending their employment contract. A “country manager” title on a business card does not by itself make someone the executive body. Pull the charter and the register extract before anyone discusses removal.

Then check whether the complaint is a whistleblowing report. The law on the whistleblowing system (HO-97-N as amended by HO-346-N) has required an internal reporting procedure since 3 August 2026 for private organisations whose average headcount in the previous year exceeded 250; from 1 January 2028 the threshold drops to more than 50. It covers reports of corruption, conflicts of interest, money laundering and other harm to public interests. A personal harassment complaint is not automatically a whistleblowing report, while a report of kickbacks or a concealed conflict of interest usually is.

Where the law applies, the internal route has fixed deadlines:

• register the report within 1 working day;
• open proceedings within 3 working days of registration;
• complete the examination within 30 days at most;
• tell the reporter the outcome within 3 days of completion.

Opening disciplinary proceedings against a reporter because of the report counts as a “harmful action” under that law, and in a dispute the employer has to prove the action was unrelated to the report. Breaches of the employer’s duties carry fines of 100 to 200 times the minimum wage, rising to 300 to 400 times where the reporter’s confidentiality is breached. Our guide to mandatory whistleblowing procedures for Armenian employers covers the procedure itself.

Who should investigate

The Labour Code does not require an external investigator, does not oblige the accused to step aside from the process, and does not regulate how interviews are recorded. It does require the employer’s internal disciplinary rules to address the prohibition of workplace violence and sexual harassment, so start by reading the subsidiary’s own rules: they may already name who handles complaints, and a procedure that ignores them is easy to attack. Our articles on internal work rules and disciplinary procedures and workplace harassment obligations set out what those rules should contain.

Three models are used in practice:

Whoever investigates, give them a mandate signed by HQ or the board, a named person to report to who is outside the Armenian line, and no role in deciding the sanction. The separation matters because in an Armenian wrongful dismissal claim the employer carries the burden of proving both the ground and the procedure. A manager challenging the outcome will attack the findings first, and findings written by the person now pressing for dismissal are the easiest target.

Whether an investigator’s notes and report can be kept out of a later Armenian court case has not been settled in our research, so write the report on the assumption that the manager and a judge will read it.

How the investigation runs

Scope it in writing

List each allegation separately (for example, inappropriate messages to one employee; personal expenses claimed as business costs; disciplinary action against a complainant), the period it covers, who commissioned the work and who receives the report. A scope that grows silently during the investigation invites the argument that the manager was never told what they were answering.

Preserve evidence before the first interview

The country manager usually has the access to delete or alter what you need. Secure copies of the expense system, card statements, approval chains and the company mailboxes of the people involved, and restrict the manager’s administrator rights over systems they could change. Do this before anyone is interviewed, because the first interview tells the manager what you are looking for.

Owning the laptop or the email server does not by itself authorise unrestricted review. The Labour Code’s rules on employee personal data and the Law on Protection of Personal Data require a lawful purpose, necessity, proportionality and minimisation, and neither contains a general exemption for internal investigations. Define the search terms and date range from the allegations, log every search and who ran it, and leave out personal folders unless an allegation points to them. Sending mailbox extracts or interview notes to HQ outside Armenia is a cross-border transfer of personal data, which the Personal Data law regulates separately; settle the legal basis for that transfer before the files leave the country.

Interview in Armenian or Russian

Interview each witness in the language they think in. Local staff giving evidence about their own manager will be guarded already, and a forced English interview produces short, careful answers that tell you little. Use a bilingual investigator or an interpreter with no connection to the office, take a full note, read it back in the witness’s language and ask them to sign it. Tell every witness that retaliation is prohibited and to whom they should report it.

Interview the complainant first and the accused manager last, after the documents have been reviewed. Put each allegation to the manager in enough detail to answer it, with the documents, and record their response in full. No Armenian rule requires interviews to be recorded; if you want audio, ask for consent at the start of each interview and note the answer.

Report in English for HQ

The report should take each allegation in turn and state the finding, the standard applied, the evidence relied on and the evidence that points the other way. Translate the key documents and quote witness statements in the original language with an English translation alongside. Keep recommendations on sanction out of the findings document, or in a separate memo to the decision-maker, so the factual record stands on its own if the case reaches court.

After the findings: suspension, sanctions and dismissal

Suspension while you investigate

Armenian law contains no express general power to suspend an employee pending an internal investigation. The Labour Code allows an employer to keep an employee from work, without pay, only where the employee is intoxicated or in other cases a law specifically provides, and an employee excluded without a valid ground can claim damages. An open investigation is not one of those cases.

What remains is an agreement: the manager accepts, in writing, a period of paid release from duties while the investigation runs. It rests on the manager’s consent, so it can be refused, and the legal effect of such an arrangement has not been tested in the material we reviewed. Corporate controls (who can approve payments, who can sign, who holds system access) are a separate question for HQ and the board.

Disciplinary sanctions and the procedure

The Labour Code allows three disciplinary sanctions: a reprimand, a severe reprimand, and dismissal on one of the disciplinary grounds listed in Article 113. Only one sanction may be imposed for each violation, and the courts require it to be proportionate to the seriousness of the act, the employee’s fault, the circumstances and their previous record.

Before any sanction the employer must ask the employee for a written explanation (Article 226). Make the request itself in writing, identify the conduct, and set a reasonable period to reply. If the manager does not answer within that period without a valid reason, the sanction can be imposed without the explanation. A sanction lapses if the employee receives no new one within a year.

The time limits

Under Article 227 a sanction must be imposed within one month of the employer discovering the misconduct. Time the employee spends on sick leave, on a business trip or on leave does not count towards that month. Regardless of when it was discovered, no sanction may be imposed more than six months after the misconduct was committed, or one year where it came to light through an audit, a financial and economic check or an inventory.

The Labour Code does not say that an internal investigation pauses the one-month period, and an ordinary investigation is not automatically an audit for the one-year rule. When an employer is treated as having discovered the misconduct depends on the facts of each case, and that point is being confirmed. Plan the investigation so that a sanction can be imposed within one month of the complaint reaching someone with authority to act on it.

Is there a ground for dismissal?

An employer can end an employment contract on its own initiative only on a ground the Labour Code lists. There is no general ground for “serious misconduct”, and neither an adverse investigation finding nor the manager’s seniority is a ground in itself. The grounds that matter after an investigation are:

• repeated failure to perform duties without good reason, which requires at least two earlier disciplinary sanctions that have not lapsed;
• loss of trust, which includes an act that caused or could cause material damage to the employer;
• appearing at work under the influence of alcohol, drugs or psychotropic substances;
• unjustified absence for a whole working day or shift.

Employment can also end by written agreement between the parties. For a senior manager facing adverse findings, a negotiated exit removes the arguments about grounds and time limits.

Notice, severance and protected employees

A dismissal for repeated failure, loss of trust, intoxication or absence requires no advance notice, and no severance is due under the Labour Code’s severance rules. The final settlement is still due on the last working day: salary to date, other earned pay and compensation for all unused annual leave. An employment contract or collective agreement can provide more.

Before acting, check whether the manager is pregnant, on maternity or other leave, on sick leave, or caring for a child under one. Dismissal in those periods is restricted, with narrow exceptions, and the exceptions differ by category.

The manager has two months from receiving the dismissal order to bring a claim, and the employer has to prove the ground and the procedure. A court that finds the dismissal unlawful can order reinstatement with pay for the period out of work, or, where reinstatement is impossible, compensation of one to twelve times the average monthly salary. If the manager is employed through an employer of record, the EOR is the formal employer and the sanction has to be imposed by it. For a review of the internal rules and the disciplinary file before a decision is taken, see our employment compliance service.

If the complaint followed earlier concerns about the manager’s background or outside interests, our article on background investigations of Armenian partners and management covers the checks that can run alongside the internal process.

Frequently asked questions

Last updated: 13 October 2026