Tone at the top: building a culture of compliance in company codes of conduct

Paper presented at the American Anthropological Association, Panel on Glitches, rollouts and stakeholders: the social life of policy jargon.
Words have a life, especially in the anthropology of policy. This panel focuses on the social dynamics of policy language, particularly the integration of bureaucratic terminology with metaphors and imagery from other fields and knowledge domains. Policy initiatives are replete with prescriptive labels that policies should be ‘evidence-based’ and that they should include sufficient transparency, accountability, ownership, reform, buy-in and partnership. Policy implementation invokes terms and images such as roll-out and glitches. Policy debate and contestation continues and enhances these terms, invoking issues of risk, governance, ethics and compliance. These terms become tools used by policy actors in forming and executing programs, by those who are its targets or stakeholders, and by the opponents of the policy agendas. Policy talk is more than terminology, more than rhetoric, and more than discourse. It is power itself. It is politics. The papers in this panel offer a comparative perspective on the production and use of policy language across policy domains (development, health, education, welfare, private sector). They add a further contribution to the burgeoning field of anthropology of policy.

Abstract of this paper ‘Policies and procedures’ are an essential part of all private sector firms. As part of the trend toward corporate ethics and the need to comply with international business regulations and anti-bribery standards, many global firms have developed their own internal codes of conduct. These codes, alongside the more specific ‘policies and procedures’, are promulgated and enforced by the firm’s ‘ethics and compliance officer’. Only by respecting the code of conduct can the firm achieve a genuine ‘culture of compliance’. But this requires a visible commitment from upper management, known as ‘tone at the top’. Without tone at the top, the code of ethics will not be taken seriously by middle management or subordinate personnel. There will be no ‘culture of compliance’. Based on research among compliance professionals, this paper discusses the terminological debates involved in the search for the right ‘tone’.