Envirocomm

Is the CCO the Conscientious Compliance Counselor?
September 17, 2012

How much accountability does the communicator in the C-suite have for influencing the company's culture? It varies, company to company, of course, but it's safe to observe that the opportunity is growing.

One analyst of corporate leadership, London Evening Standard columnist Anthony Hilton, suggested¹ that a competent company communication officer might be the right person to assume what's now the company lawyers' accountability for deciding how conscientiously the company regards laws and standards. His argument was that corporate attorneys too often take a legal compliance mentality that lets the company slip past the letter of the law, veering dangerously close to violating the spirit of the law. Lawyers aren't built to be the "conscience" of the company, in other words, and Hilton advanced the case that CCOs, attuned to culture, values and stakeholder perceptions, need to take on the role of conscientious culture advocate and enabler.

Arthur W. Page Society (AWPS) leaders come close to this view. Its 2012 research and direction report, Building Belief: A New Model for Activating Corporate Character and Authentic Advocacy, argues that the CCO has a responsibility to work across the enterprise to define and activate corporate character.

AWPS President Roger Bolton, himself a veteran in corporate culture and employee engagement in his C-suite job at Aetna, said, "From my perspective, everyone in senior management — or in the company at large, for that matter — has an obligation to build and protect brand and reputation by adhering to a strong set of values and an appropriate mission to create value for customers, employees, shareholders and society. And in the companies where I was privileged to serve, the general counsel and corporate attorneys played a highly constructive role in that regard.

The question of who should weigh in on the level of legal compliance is a case-by-case matter. There seems to be a decisive factor. Is the company content with a culture striving to simply comply with requirements, or is it trying to create, reassure and sustain stakeholders, including employees who see how close the company gets to legal limits?

Communication leaders like Bolton believe that CCOs are well situated and conditioned to weigh in on C-suite decisions that affect sustainable business cultures. "When this is done well," he said in an online commentary, "companies are focused on doing the things that are consistent with their espoused character — in essence earning trust with everything they do every day. In this scenario, compliance remains important, but doing the right thing is never in doubt."

¹writing in PRWeek UK in 2012

    Bruce Harrison is an adjunct professor in the master's program at
    Georgetown University, Washington, DC. He and Judith Muhlberger teach
    courses in leadership communications and corporate crisis communications.

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