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What Do These Phrases Even Mean?


We are all prone to using vague and ambiguous terms or cliches or buzzwords at times.

However, in my opinion, many in the compliance community seem to have developed a vocabulary all of their own that, at first blush, sounds sophisticated but in reality is merely gobbledygook masquerading as expertise.

This recent post by a respected compliance practitioner is a good example.

The main point of the relatively short post titled “A comprehensive anti-bribery policy is essential, but not enough,” seems to be that a written anti-bribery policy is a good start, but more is needed to manage and mitigate FCPA and related risks.

Fair enough, that is a rather unobjectionable point.

But in making this point, the practitioner launches into a flurry of feel-good phrases and buzzwords that caused me to scratch my head because, quite frankly, I don’t even know what they mean.

Consider the following terms.

  • “An innovative and people-centered approach towards an integrated ethics, risk management and compliance ecosystem”
  • “A code of ethics should address both the visible and invisible part of ethics in order to support associates to do what is right in their everyday context”
  • “To ensure the code is not just words on a page, it should be supported by tools and resources to empower associates and teams to make more ethical decisions and raise awareness of potential biases.”
  • “The invisible part of ethics is shaped by our work environment and culture. It is about our sense of fairness and feeling psychologically safe to speak up, for example in the case a possible act of bribery is observed. Here, we need to especially equip middle management with ethical dilemma stories and a toolkit to facilitate conversations to create an open culture where people feel safe to speak up, bearing in mind local and relevant contexts.”
  • “[I]t is all about measurement …  measurable progress on assurance levels and the company culture based on hard data, which companies are constantly gathering in all relevant dimensions of a compliance program, including culture measurement surveys.”

If anyone wants to specifically explain these concepts (and more importantly how these concepts specifically minimize FCPA risk), the invitation is open for a guest post.

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