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Corporate Compliance Insights
Home FCPA

Corporate Doublespeak

by Michael Volkov
August 2, 2018
in FCPA, Featured
pop art illustration of bribe

A Bribe is a Bribe

Why do organizations use sanitized language rather than more direct verbiage? A new generation of business leaders and employees is beginning to question the need for corporate speak. Michael Volkov discusses the need for a new approach.

Language communicates more than just words – indeed, the use of language reflects much more than simple communication. Often, a person’s language reveals an attitude, a feeling, a perspective and much more. I am often struck by how language is used by corporations to mask a clear and distinct idea. Corporate speak is a language unto itself; it can reflect a company’s culture and its commitment to honesty, trust and integrity.

Forgive me for questioning the use of corporate language, but when I read phrases such as “improper payments,” “questionable payments” and other equally vague terms used to describe flat-out bribes, I question the need for companies to avoid using accurate language. My overriding question in these circumstances is, why can’t the company use straightforward language?

A bribe is a bribe, and no matter how you characterize the payment, it is still a bribe. Of course, I recognize that in order to violate the FCPA or domestic bribery laws, a payment must be made with “corrupt” intent. In the FCPA context, a payment must be made with intent to influence a foreign official to act contrary to his or her official duties. Assuming that a payment is made with the requisite intent, such a payment constitutes a bribe.

Companies that are reluctant or unwilling to use straightforward language may choose to avoid clear and concise language. Such an attitude may reflect the company’s unwillingness to face the implications of an employee complaint, apparent misconduct by officers or employees or other problems.

The importance of language is perhaps best illustrated when companies choose to define their corporate values. The words selected by a company help to define the company’s culture, and they have an impact on every employee. The specific words used by the company are perceived by employees in a manner that ultimately is translated into employee beliefs and conduct.

Google relies on a creative mantra: “Ten things we know to be true.”

The Container Store describes a “Man in the Desert” metaphor to promote effective sales and strong leadership traits.

Corporate communications should always focus on the positive rather than informing employees what not to do. People respond to optimism and avoid negative communications. Corporate language should always fit a company’s culture – bland statements of encouragement may sound positive, but in the end fail to motivate employees.

Corporate language should weave in stories or vignettes that exemplify company values and objectives. Employees respond to goals, leadership and encouragement.

The new generation of business leaders and employees is beginning to question the use of corporate-speak, or bland business language. The focus is fast becoming the link between language and a company’s culture. New leaders are rethinking the bland use of corporate language that extracts concepts typically used in day-to-day life in the corporate world. Some are advocating for replacing corporate-speak with a human voice in a company, encouraging employees to speak to each other as humans, not as employees wedded to intracompany formalities. This trend is interesting to observe and may eventually lead to honest, open and concise language used by corporate leaders and employees. There is no reason that all corporate communications have to be conducted in a formal manner designed to avoid everyday expressions.

Going back to my original point in this posting, formality in describing a bribe reinforces the lack of clarity in corporate communications and the language used among leaders and employees.

This article was republished with permission from Michael Volkov’s blog, Corruption, Crime & Compliance.


Tags: Anti-BriberyCorporate Communication
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Michael Volkov

Michael Volkov

Michael-Volkov-leclairryan Michael Volkov is the CEO of The Volkov Law Group LLC, where he provides compliance, internal investigation and white collar defense services.  He can be reached at mvolkov@volkovlaw.com. Michael has extensive experience representing clients on matters involving the Foreign Corrupt Practices Act, the UK Bribery Act, money laundering, Office of Foreign Asset Control (OFAC), export controls, sanctions and International Traffic in Arms, False Claims Act, Congressional investigations, online gambling and regulatory enforcement issues. Michael served for more than 17 years as a federal prosecutor in the U.S. Attorney’s Office in the District of Columbia; for five years as the Chief Crime and Terrorism Counsel for the Senate Judiciary Committee, and Chief Crime, Terrorism and Homeland Security Counsel for the Senate and House Judiciary Committees; and as a Trial Attorney in the Antitrust Division of the U.S. Department of Justice. Michael also maintains a well-known blog: Corruption Crime & Compliance, which is frequently cited by anti-corruption professionals and professionals in the compliance industry.

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