Anti-bribery and corruption (ABC) laws like the UK’s Bribery Act 2010 and the US Foreign Corrupt Practices Act of 1977 (FCPA) are stringent, wide reaching and tend to carry harsh penalties for those who breach them. It is little surprise that many senior executives, especially those with a business presence in countries that have a high level of perceived corruption believe corruption poses one of the highest risks to their business in the years ahead.
You can mitigate the legal, financial and reputational risks associated with corruption by putting in place adequate policies and procedures and taking reasonable care to ensure these are understood by their entire workforce. English is considered the global language of business and it is understandable that this will be the language of choice for organisations that are located within the English speaking world or have this as the language of choice. In this situation, designating English as the ‘official company language’, on the face of it may appear to be a solution but it can in fact pose a risk to the organisation. A study by White & Case LLP highlights the challenges many firms face with international employee communications and mandatory and discretionary translations.
Some counties including France, Mongolia and Turkey have introduced prohibitions that punish employers for supplying written communication to staff other than in the local language. In less rigid settings, it is for an organisation to determine what must and should be translated based on an assessment of the local laws, necessity and proportionality. This form of assessment gives an idea of the information and documents that need to be communicated to those who do not have a good grasp of English and the most appropriate language to be used.
The serious consequences for individuals and organisations that fall prey to corruption makes it all the more important that employees, third parties and clients should know the official line and their responsibilities in this area. For example, guidance on what an organisation deems to be acceptable in respect of gifts and hospitality can vary considerably and should not be left open to interpretation. Defining acceptable practices in ‘plain English’ alone can be tricky and ensuring this information is conveyed clearly within a translation is crucial.
It is reasonable therefore to expect that a member of staff who does not have a good grasp of English, should be supplied with either a translation of the Anti-Bribery procedure that is in their mother tongue and crystal clear or have it explained to them by a linguist who is highly proficient in both languages. The same principle can be applied to other procedures that need to be understood by staff but are written in a language that they cannot understand. Opportunities to enhance employee relations and mitigate risk of harassment by translating HR policies on acceptable behaviour is viewed as good practice by corporate investigations firm i-sight who have warned that English communications can land multinationals in regulatory hot water.
The languages of the world are rich, colourful and often different. Those who suffer as a consequence of corruption know the devastating damage it causes them and wider society. Corruption is not a crime that sits in isolation – it is the food that gives life to other dangerous entities. Where bribery and corruption are present, evidence shows that other criminal activity such as money laundering, fraud and cybercrime (including intellectual property theft) are also more likely to exist thereby increasing an organisations exposure to crime risk.
Ensuring that your plain English ABC policy translates accurately into ‘plain multilingual’ is a science that has no room for error. To ensure that Today Translations’ own policy and procedures are clear, they have been translated. A generic version of these has been created and can be downloaded from the links below. These provide you with an idea of how a policy can be translated. Today Translations can translate, culturally adapt and independently certify your policies as well as assisting you with the creation of multilingual training material; multilingual media including voiceovers and subtitling; and due diligence research.
Vital information can be hidden in translation. Today Translations are the world leaders in the field of spotting those risks and minimising your exposure. When you need that reassurance, the team at TT are your perfect partner.
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