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This paper is a comparative critical discourse analysis of Chinese and British insurance contracts. It analyses the similarities and differences in the identities that emerge from the situatedness of the insured and the insurer in the contracts in order to determine the extent to which the sociocultural context within which the texts were conceived shape the texts. The study draws on the positioning theory and the notions of situated identity/situated meaning and is informed by analytic tools within critical discourse analysis. It found that in both the Chinese and British contracts, the insurer is linguistically and discursively situated as a powerful and resourceful ‘regulator’ (i.e. an active force) whereas the insured is mostly constructed in subjective and somewhat ‘weak/vulnerable’ terms. This similarity notwithstanding, the study found differences in terms of the kind of power relation, the level of formality or social distance and the dominant type of language evident in the two contracts. The Chinese contract was found to display a much stronger power relation and a more highly/strictly level of formality than the British contract. And whereas the Chinese contract was predominantly couched in very legal terms, the British contract had a more businessoriented focus. These differences demonstrate how (insurance) discourse may be shaped by the social and cultural contexts in which it is conceived and, possibly, sculpt the identities ofall those addressed.
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