Aaron Lewis

For the last few years, an important part of Lewis’ practice has involved investigations he describes as “special matters,” in which corporate boards and executives seek his and Covington’s help to assess internal problems and risks involving bias or discrimination.

Although most of those matters are confidential, he and his team did release their report early last year about Starbucks’ efforts to combat racial bias following the high-profile arrest in 2018 of two Black men at a Philadelphia store as they waited for a colleague to arrive.

“One of the core problems we grappled with was how you deal with the concept of implicit bias in retail across sectors,” Lewis said. “I was very impressed by how deliberate and thoughtful the company was. … They really leaned forward and wanted to grapple with the topic.”

Since then, he has led or co-led similar investigations, such as one for a global professional services firm concerned about internal barriers that might deter Black employees from reporting discrimination or insensitive treatment.

For a life sciences company, he conducted a more focused investigation into whether the CEO had violated the company’s personnel policies and code of conduct.

Lewis also frequently leads the more typical probes into whether a company or employee committed any criminal or regulatory violations. “I pretty commonly represent aerospace and defense companies that are facing either civil or criminal fraud investigation,” he said.

Late last year, he represented a global aerospace firm under grand jury investigation for alleged procurement fraud. By May, federal prosecutors had closed their case and declined to bring criminal charges against his client.

Lewis, who started in practice as white collar investigations associate with Covington, said his work on anti-discrimination “special matters” has been a surprise and a revelation to him. But those cases are like his more traditional matters because they all involve questions of compliance, he said.

“You can’t really have a strong culture of compliance simply for regulatory enforcement if you have a weak culture of compliance in your workplace generally in terms of how your people treat each other,” he said. “There are controls that [you] can put in place around people, anti-discrimination, just as there are controls you can put in place around accounting or procurement or trade or anti-corruption.”

— Don DeBenedictis