The immediate priority is to establish a disciplined factual picture. That means identifying the relevant documents and people, preserving key materials, and separating what is known from what still needs to be tested.
At the same time, the business needs a clear internal cadence. The right group should receive concise updates, with decision points and communications carefully coordinated so that operational activity does not outpace the legal strategy.
An early focus on facts, options, and governance does not predetermine the outcome. It creates the conditions for a response that is measured, credible, and proportionate to the issue.