Companies are increasingly using written ethical codes to communicate their prin ciples and practices; however, there have been few attempts to examine the complex lan guage decisions the composers of such documents are likely to face in their attempt to "manage" the differing expectations of their readers. To reveal some of the rhetorical concerns that arise in constructing a code that is truly affiliative and inclusive of the readership and yet reflective of the goals of the corporation itself, this study focuses on the Dana Corporation's code. Using the standard linguistic technique of substitution to examine possible alternatives, especially the ways in which Dana refers to itself and its employees, brings to light some of the subtle rhetorical decisions that composers of ethi cal codes need to negotiate.