I would imagine so. There has to be a non-verbal or symbolic channel of communicating that then provides official deniability.
As an example take discrimination and at-will employment. Let's say the owners want to fire a gay guy. They can't fire him officially because of various discriminatory laws so they maybe invent a non-verbal or a code word 'restructuring' so they lay him off due to restructuring.
In general part of operating in large bureaucratic institution is to learn:
* what rules can be broken (break them if you like but don't force the management to make an official statement on it and don't ask permission on paper)
* what rules should be broken ("you need to torture this guy and it is illegal so we'll just use a euphemism -- 'interrogation' you know what I mean, I know you know what I mean, but we can never write that down in an email")
* what rules cannot be broken, official and un-official (some things are never tolerated what these are have to be discovered carefully as these might not all be written down, say who can disagree with the boss during a requirement meeting... it is not written down but if you are part of the wrong group, you won't fare well)