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May/June 2000 - By Andrew W. Singer

United Parcel Service Translates and Transports an Ethics Code Overseas

If a company thinks that delivering an ethics code to its overseas business units is a simple affair, it might think twice. United Parcel Service (UPS) knows better.

The giant Atlanta-based delivery firm has had a code of business conduct for its domestic employees since 1996. Because UPS operates in most countries of the world, though, it realized it needed an international version. In 1998, it began working on one, conducting research and benchmarking with other companies.

From the start, the company displayed unusual cultural sensitivity, hoping to avoid imposition of an "American-centric" code on its overseas’ businesses. Ethics Officer Association (EOA) conference presentations provided some guidance in this regard, recalls Linda DiSantis, Corporate Compliance Manager. UPS developed advisory committees in different regions, including Europe, Asia, and the Americas. Committee members represented not only different countries, but also different job functions. Not all were human resources professionals.

Wanted: translations into local language

The U.S. code of conduct became the centerpiece of employee focus group sessions that were conducted around the world—16 in Europe, ten in Asia, four in Canada, and five in the Americas—in the third and fourth quarters of 1998.

What did employees like about the code? What did they not like? In the course of these sessions, training gaps were revealed. An Irish employee, for example, asked, "What is the Foreign Corrupt Practices Act?" (Even though it is a U.S. statute, the FCPA applies to UPS’s foreign employees.) Above all they found that "employees wanted the code translated into their own language," recalls Anna Svärd Thompson, Corporate Compliance Coordinator.

No particular areas of the domestic code were problematic, recalls Thompson, but the company was urged to attach sections in some cases. In Europe, a section on data protection was added because that, along with privacy, is a prominent issue among European Union nations.

References that applied only to the United States, like baseball, or allusions to U.S. government agencies, were removed. After going through various drafts, the codes were shared with advisory committees. One committee suggested adding a question and answer (Q&A) section after each policy, based on questions that were raised in the focus group sections. One such question: Can employees sell Girl Scout cookies at work? (for the U.S. code), or, alternately (for Europe): Can employees raise money for charitable causes at work? (The answer to both is no.)

The handling of gifts and gratuities was customized for different regions, although the basic UPS policy remains the same in all countries—one cannot receive expensive gifts. (There are no specific dollar limits, however.)

The Q&A section in the Chinese ethics training manual, for instance, used an example from the Chinese New Year festivities where it is traditional to issue small packages with a ‘tip’ enclosed to UPS drivers. "We said that is fine," because it is really of nominal value, recalls Thompson. Moreover, if the drivers declined it, it might embarrass the givers.

With more expensive gifts, though, "We advise them to accept it, and immediately take it to their supervisor," says Thompson.

Taking the hotline abroad

Focus group sessions revealed some problems, too, with the company hotline, initially called the "Conduct-line." In Asia they were told: "It’s not something we would do," that is, report on another employee. "That would be like taking someone’s life." There was also resistance in other places, like Germany, where totalitarian memories (e.g., neighbors encouraged to ‘report’ on neighbors) were still alive.

The ‘Conduct-line’ name was a problem, too, the foreign employees suggested. If it were renamed the ‘Help-line,’ overseas employees might be more inclined to use it. The latter suggests guidance. ‘Conduct-line,’ by contrast, suggests ‘snitching’ on somebody. The change was made. "Employees do feel more comfortable with the name change," says Thompson.

That said, DiSantis observes that most international businesses don’t generate many Help-line calls. It remains something of a "cultural issue." Nonetheless, UPS has interpreters ready to assist with Help-line calls, another idea that came out of the focus group sessions.

After receiving further feedback from the advisory committees, they set to work translating the code, training manuals, and posters into 28 languages. Here they used Omni Resource Group, a multi-lingual services provider based in Atlanta.

In some cases they made multiple translations in the same basic language. There were separate translations for (Portuguese-speaking) Brazil and Portugal, for instance. France and French Canada, and Spain and Latin America required separate versions of French and Spanish, respectively.

Why bother with a distinct translation for French Canada? Residents of Quebec demand a "more purist" French, explains Victor Warners, Omni’s vice president. They are less tolerant of anglicisms than are citizens of France.

Another challenge was "adopting a tone appropriate for each country," recalls Warners. When addressing Americans, the tone of the code could be more informal. "But others prefer something more formal—paternalistic, almost." Germans wanted something with more authority, he suggests.

Concepts were sometimes difficult to translate. "In the Arab world, if you tell them not to take an official out to dinner, that is looked upon strangely," notes Warners. "Bribes are a daily occurrence."

Alcohol consumption was a sticking point in some places. UPS has a policy that if an employee drinks alcohol at lunch, that person should not come back to work in the afternoon. The French couldn’t quite grasp that. A glass of wine at lunch, after all, is part of the culture.

Each of the 28 versions required a translator and an editor—56 people altogether. In addition Omni used 5 different typesetters and two project managers: one for the translations, the other for the type-setting and production.

Once a translation draft was completed, it was taken to subject matter experts—"language specialists" in this case—to scan the work for "strange translations" or old fashioned terms. They uncovered some interesting errors. In one instance, the term ‘antitrust’ was translated literally as ‘against trust.’

Translating ‘honesty of purpose’

Some things just didn’t work in translation. A key phrase in the domestic code, "honesty of purpose," coined by the company’s CEO in the early 1990s and regarded as part of the company’s legacy, just did not translate. It was replaced with "leadership with integrity" in some instances, although it remained "honesty of purpose" in the U.S. code.

The company required language experts to "interpret back to us in English certain sections, just to make sure that they had looked at them," says Thompson.

The foreign codes were designed, laid out and printed by the second quarter of 1999. The typesetting and production was something of a "nightmare," according to Warners. Omni created a basic layout, or container, for all versions, to give the code a uniform look. But when they tried to fill the ‘container," things didn’t always fit snugly. Arabic, for instance, is written from right to left, not left to right, creating some difficulties. Some languages could be typeset on a PC, others had to be done on a Macintosh. Some languages were well suited for the Quark publishing software program, others had to be done on Pagemaker. One font might be used in some languages, but not others, because it lacked a certain accent.

Another difficulty concerned the Help-line posters. How does one make an ‘800’ telephone number available overseas—given that one can’t use 800 numbers from one country to another? UPS wanted the calls to be toll-free, and it wanted to receive them in the United States. Their solution was to employ the calling-card access number used by UPS employees for international calls, along with the 800 number. This got the call to the U.S., but it also meant that UPS had to have country-specific posters, since each country has a different calling-card access number.

Employees in 42 countries

Not every locale where UPS operates received a local translation of its code. But every country in which UPS has a wholly owned subsidiary—where it actually has employees, as opposed to operating through local delivery companies—received a translation. UPS has employees in 42 countries, although it operates in almost every country in the world.

Once the codes, training manuals, and posters were completed, international training leaders were brought to Atlanta to attend "train the trainer" sessions. Training materials were dispensed in English, German and Spanish only; this was feasible because most trainers speak English.

In the middle of year 2000, the codes were also posted on the company’s web site in 28 languages.


Wasn’t all this a somewhat expensive process? "We did a lot of work internally," recalls DiSantis. "We let our own people manage the focus groups," usually someone from human resources—as opposed to outside consultants. (A consultant did advise them at the corporate compliance level, however.) That helps defray the cost. "But translation is obviously not inexpensive." Overall, though, "it is a manageable amount of money," says DiSantis.

Are there lessons for other companies here? "Keep communication open," says Thompson, through such things as focus groups and advisory boards. Early on in the process, for example, UPS put together an International Compliance Committee, comprised of senior people in international operations. This was important in generating useful feedback. It enabled foreign managers to "understand what you’re trying to do." Otherwise, they may react: "This is a U.S. thing; it only pertains to the U.S. Why are you taking this over to us? We have our own policy.…"

Adds DiSantis: "The way we dealt with focus groups and advisory boards gave us a broad base." All management people now receive the code of conduct in their initial training.

About 35,000 international employees received the code in their local languages (the company has 359,000 employees overall). The process was essentially completed by March 2000.

Andrew Singer is Co-Editor of ethikos.
Reprinted from the May/June 2004 issue of ethikos.
© 2004 Ethikos, Inc. All rights reserved.

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