Every compliance officer in the United States knows that translating our expectations about business conduct into terms that overseas employees can understand is a daunting task. So if you're looking for one specific example to demonstrate the problem to your board or CEO, I'd suggest dropping by the FCPA Compliance Group on LinkedIn.
A discussion thread posted to the group last week talks about training Latin American employees on the Foreign Corrupt Practices Act, and buried halfway down the comments is this little gem: that the Spanish language has no word for “whistleblower.”
My Spanish is rudimentary at best, so I take this statement at face value. But it comes from Bruce Horowitz, a U.S.-trained lawyer who now makes his living practicing law in Ecuador, and he would know better than most. His words:
The words soplón and chivato are already in use, but they both start out with the negative connotation of “snitch.” A direct translation of the metaphorical “whistleblower” could be a made-up word, such as pitador, related to pitos (the whistles used by sports referees and police officers). The verb pitar even contains the sense of a loud vocal protest, such as “to boo,” which is much more positive than “to snitch.”
We rarely get into matters of linguistics at Compliance Week, but this glimpse into the subject perfectly underlines the challenges compliance executives have—namely, that you can't even assume you have the correct words to educate employees, much less the systems, executive support, and legal standing to deliver on your broader compliance mission.
I remember my Communication 101 course back in freshman year at college, and the very first concept we learned was that two people must have a common frame of reference if they ever hope to communicate anything. Apparently, despite all our talk about living in a globalized village, in some instances compliance is still stuck on that.