Are We Sure of the Impact of Anti-Corruption Messages?
It suffices to have attended half a dozen conferences on compliance and anti-corruption to hear two corporate mantras: the necessity of the tone from the top, and the importance of role models…
Naturally, I do not intend to totally deny either of these but there are, in my view, flaws and dangers in relying on them too heavily.
The «tone at the top » already contains an inherent ambiguity. Indeed the issue at stake is not the "tone at” but the "action from” the top. Moreover, to suggest that the tone at the top is the single pillar of a culture of compliance entails a risk of deresponsibilisation in particular at the lower end of the spectrum of the chain of command. Most of the difficult cases that I have encountered in my practice came from the ground level and the frontline rather than from the top. And as we are talking about misleading messages let me note that a fish does not stink from its head…it stinks period. In fact any fishmonger will tell you that the first criteria for knowing how fresh is the fish is to look at it in its entirety.
This leads to the other mantra I often encountered in companies: the role model. A number of companies rely on this idea and identify internal or external figures as anti-corruption champions or ambassadors. According to the Cambridge Dictionary: “a person who someone admires and whose behavior they try to copy.” Here again let me note that someone can be admired for good or bad reasons, but more importantly a company that stakes too much on its role models may face disillusionment and cynicism if the role model fails.
Those two examples show the difficulty of anti-corruption messaging. In fact at a broader scale several studies indicates that “there is growing concern that anti-corruption awareness-raising efforts may be backfiring; instead of encouraging citizens to resist corruption, they may be nudging them to ‘go with the corrupt grain.’”*
Compliance should be everybody’s day-to-day business, often below the radar and not very exciting in terms of communication. It is certainly useful in any company to send short and catchy messages to focus the mind of all employees as long as it is clear to all that such short and catchy messages will never replace a solid and well articulated compliance program."
International Lawyer, Former Director for Legal Affairs, OECD