Multinationals' corporate codes of conduct are meant to guide employees throughout organizations. Research draws attention to their problematic cross-cultural transferability but hardly ever considers whether a monolingual version or a translation into employees' mother tongue is used, making language a non-issue. A position disproved by empirical work on the diverse understandings of values formulated in English as a lingua franca or on translation negative impact when employees do not recognize themselves in the personnel depicted. Drawing upon the translation (from English into French) of a specific code of conduct that embeds it in the local culture, I contend that translation is the key to corporate code cross-cultural transferability. Articulating a cross-cultural discourse analysis (using semantic, syntactic and enunciative categories) of the source and target texts with a culture interpretive approach (d'Iribarne, 1989, La Logique de l'Honneur. Paris: Seuil.), I 'deconstruct' the translation process and show how the combination of apparently insignificant linguistic modifications-that is, collective staff designations replacing individual ones or vice versa; moral qualities turned into social or professional merits; and so on-make the target-text steer away from the initial cultural context and set action in a new cultural setting likely to entail a similar effect on the staff. The cultural underpinnings of the translated code find confirmation in local organizations' corporate codes of conduct as well as in literature on the targeted country. The findings also highlight the fact that the transposition of the corporate code core notions brings about different manners of putting them into practice. Applying such an interdisciplinary approach to explore either locally produced or translated corporate codes of conduct could highlight the beliefs and business norms acceptable here and there and help practitioners to successfully perform the advocated cross-cultural transfer of corporate codes of conduct. Keywords Corporate values, cross-cultural discourse analysis, cross-cultural transferability of corporate codes of conduct, culture interpretive approach, English as a lingua franca, French, translation