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Exemplary organizations, people, and processes provide ethical guidance to members of the marketing communication industry, involving practices of advertising and public relations. Wire and Plastic Products (WPP) is a unique case due to its size, reputation, inclusion of advertising and public relations, and use of ethical codes. WPP, the world’s largest agency, is a British, multinational advertising and public relations company holding approximately 350 marcom companies worldwide with approximately $19 billion in revenue. This rhetorical criticism of the WPP Code of Business Conduct, and related website content, calls upon Kantian ethics to examine the symbols therein to determine if the Code could be viewed as exemplary for the industry. While the Code suggests that, overall, WPP companies have an obligation to behave honestly, with integrity and to respect others, for some subsidiaries, vague examples, hyperbole, and contradictions emerged.


advertising, code of ethics, marcom, marketing communications, normative ethics, rhetorical criticism

A Brief Introduction to the Authors.
Video 1

A Brief Introduction to the Authors.

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Fig. 1. An executive from a WPP subsidiary provided this image in her blog about the WPP Code of Conduct Training, which is one facet (among many) of how a global advertising conglomerate articulates its ethical standards.
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Fig. 1.

An executive from a WPP subsidiary provided this image in her blog about the WPP Code of Conduct Training, which is one facet (among many) of how a global advertising conglomerate articulates its ethical standards.1


The ongoing debate about ethics reemerges when evidence of wrongdoing –among reputable marketers hits the news. In the wake of a scandal exposing Volkswagen products designed to cheat on emissions tests, the company pulled its national advertising saying that the revelations “drowned any positive messaging.”2 Brands such as Kellogg’s have reduced online spending because publishers such as Facebook do not verify the viewership of ad placements.3 The Federal Trade Commission (FTC) released new standards for labeling native advertising as “advertisement” after holding a conference called “Blurred Lines” discussing native advertising’s lack of transparency.4 The FTC found that the labels “sponsored by” and “promoted by” were too misleading and led readers to assume that the content was journalistic and not advertising.5 These are just a few of the many examples serving as fodder for the discussion of marketing communication ethics.

While scholars have found evidence of ethical decision making in advertising, and moral reasoning in public relations,6 both trade and academic literature focuses on ethical problems such as using deceptive messages and promoting harmful products.7 However, media ethicist Lee Wilkins argued that like journalism, advertising is essentially information, and that “assertions that the entire practice is unethical are unsustainable.”8 In public relations, both educators and practitioners agree it is the responsibility of the practitioner to accept the role of ethical conscience,9 and uphold a duty to self, client, society, employer, and to the profession.10 The current study suggests that to encourage a sustainable, ethical marketing communications (marcom) industry, which includes advertising and public relations practices, exemplars are needed. Moral exemplars are defined as people who behave ethically, organizations that espouse ethical values and engage in ethical decision-making, and organizational artifacts that guide ethical decision making.11 Focusing on the latter, organizational artifacts serve as a resource for organizational actors faced with an ethical dilemma. While contradictory findings have questioned the extent to which codes of ethics can influence ethical decision making,12 codes can serve as a normative framework that practitioners prefer to see adopted in formalized training programs, because they provide compliance structures for guiding future action.13 Descriptive norms (what we think others do) have been shown to predict ethical behavior in the context of journalism practices, suggesting that leaders should “regularly recognize and share with their staff instances in which employees (or other colleagues) have acted ethically.”14

Marketing communication is ubiquitous throughout the world. Through rhetoric, defined as communication with a persuasive intention, advertising and public relations agencies that comprise the marcom industry ask their audiences to think or look at the world in a specific way. Therefore, it’s imperative this communication, and its creators, are guided by ethical standards, such as an organizational code of ethics. In this article, Wire and Plastic Products (WPP) was selected for analysis due to its size, reputation, inclusion of advertising and public relations, and use of ethical codes. WPP, a British multinational advertising and public relations company and the world’s largest agency, holds approximately 350 marcom companies worldwide and had $19 billion in revenue as of 2014. In addition to its size, WPP proves a unique case due to its espoused ethical code of conduct, which states that all WPP companies behave under the “values of honesty, integrity and respect for people” and that “these core values determine the way we approach business and they define the principles in which we expect our people to behave in the conduct of our business.”15 In addition to espousing core values on its website, WPP publishes the Code of Business Conduct and requires all employees within its network to pass an ethical training course during the first few months of employment.16

Codes of conduct have exemplary potential, which suggests they model good behavior for others that, when adhered to, allow an organization to self-regulate thus avoiding external regulations, which is good for business and the industry. With its robust size and reach, WPP provides an ideal case to explore the extent to which an organization and its code of business conduct has the potential to set an industry example. Analysis of codes is often limited to two moral frameworks: deontology and virtue-based theory.17 Kantian ethics is a deontological, duty-based theory, which suggests what each individual’s moral obligation is versus what virtuous character an individual possesses (i.e., virtue theory). Deontological theory is one of several normative frameworks that suggests what is right and good and ought to be done. A Kantian approach appears suitable when one considers that marcom practices are traditionally defined as duty based, such as PR practitioners’ obligation to serve as their clients’ “organizational conscience” by providing ethics counsel when problem solving.18

The current study, guided by Kantian ethics, employed qualitative analysis. This rhetorical criticism of the WPP Code of Business Conduct examines the symbols therein and the intended meaning of these symbols to determine if the Code is an exemplary resource for the industry. While the WPP Code of Business Conduct suggests that WPP companies have an obligation to behave honestly and with integrity, and to respect others, contradictions emerged. A detailed presentation of these findings follows, preceded by a review of deontological theory and rhetorical criticism, as they apply to codes of ethics.

Literature Review

Advertising and public relations practices rely on communication, which is inherently ethical in nature. Much like ethical decision making throughout various aspects of people’s personal and professional lives, marcom ethics occurs in light of multiple and often competing loyalties and responsibilities. Advertising ethics has traditionally been defined as normative, what is right or good and what ought to be done.19 In response, codes of ethics have been developed, such as those adopted by the American Association of Advertising Agencies.20 Similarly, the Public Relations Society of America has its own set of ethical codes.21 While often demarcated in literature, advertising and public relations practices are continuing to blur in practice.22 What were traditionally considered responsibilities of public relations practitioners are now exercised by advertising practitioners, and vice versa. Therefore, a code addressing the practices of both advertising and public relations, such as WPP’s Code, seems advantageous to advancing the ethics of marcom collectively. Before reviewing codes of ethics, it’s important to understand how they serve as rhetoric.

Rhetoric and Ethics

The values and ethics in all human communication are often unacknowledged and swim beneath the surface of superficial messaging. A rhetor intends to achieve goals when communicating, although those goals may exist at different levels of self-awareness on the rhetor’s part. Goals might be to inform an audience, for example, such as the creator of a WPP subsidiary website who writes copy to inform a prospective client of the agency’s services. Whether a rhetor communicates to inform, entertain, persuade, or connect with others, any communication interaction has consequences, large and small, intended and unintended. Thus rhetoric, regardless of its form or content, always carries values and ethical dimensions.23 Richard Weaver, historian and philosopher, in his discussion of language as “sermonic” writes that “we are all of us preachers in private or public capacities. We have no sooner uttered words than we have given impulse to people to look at the world, or some small part of it, in our way.”24

An interpretivist perspective offers a useful basis for the rhetorical analysis of organizational communication in this study. This perspective holds that one should conceive of organizations as socially constructed based on the beliefs, actions, and communication of organizational members and other stakeholders.25 Educators George Cheney and George Dionisopoulos, and educator Michael Pacanowsky and graduate student Nick O’Donnell-Trujillo in their respective articles argued that traditional studies of organizational behavior have offered linear and incomplete conceptions of “transferring, processing, and storing subsystem or environments information … and organizations [as] information processing systems.”26 Therefore organizational analysis is often superficial in nature, focusing on the process and related outcomes, while failing to recognize the social nature of these processes. Combating these limitations, others have emphasized the symbolic and rhetorical nature of organizations.27 Professor of organizational behavior Jeffrey Pfeffer suggested that “one of the principal tasks of management [is] to construct and maintain systems of shared beliefs and meanings.”28 Therefore, examining codes and values is a means of understanding the social nature of organizations by deciphering the shared meaning that exists within organizations.

Furthermore, shared belief is the basis of organizational culture, which is comprised of internal and external members working together to achieve goals in face of challenges, resulting in the basic assumptions, values, and artifacts that are perceived to be valid and therefore shared with new members.29 Examining codes provides insight into organizational culture. An organization’s ethical culture and the associated artifacts used to uphold this culture help to shape what behaviors are perceived as acceptable or unacceptable by both internal and external audiences. If shared meaning is perceived by external audiences as well, to what extent might a code of conduct serve as an example for others outside the organization, and could a code be morally exemplary? A review of moral exemplars follows.

Organizational Artifacts and Moral Exemplars

Edgar Schein, organizational culture scholar, argued that to understand an organization’s culture and how it acts in the way it does, it is important to study three distinct levels of analysis: artifacts and behaviors, espoused values, and assumptions.30 The current study examines the WPP Code of Business Conduct, and related ethical values on organizations’ websites encompassing two of Schein’s noted levels: artifacts and espoused values. The Code is an artifact of the organization, while the text of the Code represents the organizations’ espoused values, which lead to one’s understanding of basic underlying assumptions. Together, the artifact and values therein represent dimensions of organizational culture providing data triangulation even when the environment (and behavior therein) cannot be observed. When taken together, these two levels of analysis lead to a greater understanding of an organization’s culture in terms of ethical decision making, without actually observing the organization.

According to communication scholar Joann Keyton, an organization’s cultural artifacts are visible and tangible, such as a dress code, philosophy of leadership and ethical codes.31 Ethical codes are “systematic descriptions and articulations of the organization’s formal position with regard to values and ethical positions.”32 Codes provide several purposes, such as clear moral guidance to members of an organization, limits on employee behavior, and evidence of an organization’s acceptance or condemnation of certain behavior. Codes also serve as a public relations device.33

Codes of conduct can be instituted by a profession, such as the American Association of Advertising Agencies (4As) “Standards of Practice,”34 or, as aforementioned, an organization, such as the WPP Code of Business Conduct. Professor Mark Somers suggested that unethical behaviors are perceived to be less prevalent when organizations adopt a corporate code versus adherence to a professional code of ethics.35 Furthermore, a corporate code of ethics is good for business, allowing organizations to self-regulate by implementing a standard of ethics to avoid external standards and regulations, which can be time-consuming and costly processes.36

Yet the roles of codes of ethics in professions in general, and in marcom in particular, are fraught with controversy. Media ethicist Chris Roberts points out that in persuasion industries, such as advertising and public relations, codes often reveal common problems.37 First, they often are internally contradictory by failing to specify to whom organizational members owe loyalty. For example, the Edelman Public Relations firm’s extensive code of ethics includes the commitment to be “faithful to our clients’ needs.” The next part of the code says, “we balance the needs of our clients with the obligation to serve the public interest and our profession.”38 Thus, it’s unclear if one obligation supersedes another, how an employee should know how to balance competing loyalties, and what decision-making criteria she should use.39 Another limitation is the rhetorical nature of codes. Codes can use abstract terms and generalities, or they might be aimed at convincing publics that advertising and PR firms have strong standards, therefore serving as reputation management for the marcom organizations. However, in day-to-day decision making, these codes are then rarely consulted.40 Finally, codes can limit autonomy by providing specific instructions that limit an employee’s ability to critically problem solve relative to a specific situation, one that is unlikely replicated in an organization’s codes of ethics.

Nevertheless, authors have argued that well-written codes using precise language can offer important benefits.41 Such codes can educate newcomers and remind current employees of a firm’s standards. They might also serve to focus attention on current and potential problem areas and stimulate discussion among internal and external stakeholders. Professionals who work with media, such as marcom executives, are in constant need of guidance, since technology has enabled practices with ethical implications such as programmatic ad buying (i.e., the algorithmic, real-time process of buying and selling advertising space, which is hard to track and therefore to accurately bill clients), and behavioral targeting (i.e., the tracking of an individual’s online behavior such as the sites visited, which has implications for one’s privacy). Formal codes offer a set of standards, values, and principles that can offer guidance for considering proper or improper behavior in a given situation.42 Therefore, formal codes of ethics are a rhetorical tool that can encourage, persuade, and exhort an organization’s members to aspire and adhere to a set of standards, and “codes of ethics must become a balanced part of a complete ethical framework for practitioners.”43

By setting ethical standards, behaving ethically, and depicting duty beyond self-interest, an organization, in its communication with internal and external audiences, sets examples for others. An organization can therefore serve as a moral exemplar showing actions that others could adopt. A moral exemplar models ideal moral living but, being a moral exemplar, does not assume moral perfection is attained.44 For instance, in a qualitative case study of a pharmaceutical manufacturer, organizational culture played a predominant role in the organization’s serving as moral exemplar.45 Within the organization, management supported by ethical values and ethical training guided ethical decision making. The author argued that the organization, well known for placing a premium on “ethical decision making and open communication,” substantiated it as a moral exemplar.46

This article seeks to understand the extent to which an organizational artifact can serve as exemplary, specifically, WPP’s Code of Business Conduct shared with the organization’s roughly 350 subsidiaries. To examine the extent to which the code is morally exemplary, the study first asks,

RQ1a: How does WPP Code of Business Conduct, if at all, serve as a moral exemplar for marcom organizations?

RQ1b: How, if at all, does the rhetoric on WPP companies’ websites uphold WPP Code of Business Conduct?

The practices of marcom are constantly evolving and fraught with ethical implications. To guide decision making in response to these practices, guidance is needed such as that provided by a code of conduct. However, a code is only as good as its normative nature, by prescribing what is right and good. A review of Kantian ethics, a normative theory of morality, follows.

Kantian Ethics

Normative theories of morality suggest what behaviors are good and should be performed. For example, consequentialism views the “rightness” of a decision or action based upon outcomes or consequences of one’s action. Deontology, by comparison, is a non-consequentialist moral theory that defines the rightness of a situation by one’s moral duty. Immanuel Kant’s ethical philosophy is deontological, duty-based moral reasoning. Kantian theory is concerned with consistency, fairness, autonomy, and respect. To maintain consistency and fairness as ethical duties, Kant proposed the categorical imperative. The categorical imperative holds that when an individual makes a choice, she must consider what would happen if her action or behavior were performed by everyone, meaning the action is constituted as a universal law.47 For Kant, the categorical imperative was to always tell the truth regardless of the circumstances: Even if a murderer was knocking on your door asking if you were harboring his next victim you would be morally required to answer honestly.

Regarding autonomy and respect, Kantian theory insists that one’s moral requirement is to respect human dignity and to treat others as ends and never as mere means.48 Similarly, transparency is a key concept in media ethics, as well as business in general, acknowledging the consumer as an end versus a means. As Plaisance writes, transparent behavior is the “… conduct that presumes an openness in communication and serves a reasonable expectation of forthright exchange when parties have a legitimate stake in the possible outcomes or effects of the communicative act.”49 Therefore, transparency as a duty acknowledges the moral dimensions of communicative acts, without disregarding the need to protect a person’s autonomy and privacy.50 An exchange in advertising doesn’t just occur between agency and consumer; exchanges also occur between agency and client, agency and vendor, and client and consumer, often mediated by an agency. Therefore, transparency ensures all players speak the same language.51 Yet transparency is often debated in advertising ethics scholarship, most recently regarding native advertising.52 The example of native advertising, persuasive content intended to blend in and mimic editorial content, illustrates that while duties such as transparency might remain unchanged, their need to be evaluated is constant in light of emerging practices. And as the media landscape continues to innovate new practices, it’s important advertisers understand and continually revisit the moral nature of transparency to guide their current and future activities. Therefore, the present study asks,

RQ2: To what extent do the rhetoric of WPP Code of Business Conduct and the rhetoric of WPP companies’ websites represent Kantian ethics?

Ethical codes serve as a resource for guiding ethical decision making. Examining codes from a Kantian ethics perspective provides insight into the extent to which these codes illustrate duties such as fairness, autonomy, respect, and transparency, that might be continually upheld and serve as categorical imperatives in response to new and evolving practices.


This article employs rhetorical criticism, a qualitative method of analysis, to examine how a media conglomerate’s business code of conduct might serve as a moral exemplar for its agencies, as well as the marcom industry overall, and what the code reveals for advertising ethics. Rhetorical criticism has been used to examine websites,53 ethical codes,54 and advertising agencies.55 Rhetorical criticism suggests language is purposeful, including the purposeful use of symbols, to generate a desired response.56 Rhetoric is defined as “the human effort to induce cooperation through the use of symbols.”57 For example, industry leader Michael Rosen observed symbols of organizational culture, such as speeches and awards at an annual advertising agency breakfast, and suggested that these symbolic acts reinforced the bureaucratic structure of the agency and to encourage employees to work hard to achieve unified success.58

The present article identified WPP as an appropriate site for study based on its large size, its many marcom subsidiaries, and its use of ethical codes. WPP’s approximately 350 subsidiaries include advertising, branding, digital, entertainment, public relations, sports marketing, and talent agencies. The following process identified WPP companies for inclusion in the rhetorical criticism, to reduce the sample to a manageable size. The units of analysis were WPP companies’ websites. The media instance, which is the date range in which the URL was captured and analyzed,59 began on March 10, 2016,60 yielding 356 company names, and analysis continued through March 30. To help reduce bias when selecting websites, a random start was used. After a random start using a random number generator, every 4th company was selected until a systematic random sample of 100 companies was yielded.61 The process then involved two analysts, independently reviewing 50 sites each for manifest and latent content, and then discussing which cases to select for criticism. The analysts looked for manifest content,62 which refers to the explicit mention of “ethics,” appearing within the homepage or any subsequent links and navigational pages related to ethics, to the organization, or to organizational culture such as, but not limited to, pages identified by “about us,” “culture,” “codes,” “ethics,” etc. Analysts also looked for latent content, which is the contextual references related to ethics, as well as related to keywords identified in the WPP Code of Business Conduct (see Appendix B) such as “appropriate,” “code,” “honesty,” “integrity,” “law,” “obligation,” “offensive,” “respect,” “responsibility,” and “value.” The process resulted in the selection of 13 websites (see Appendix A).

Next, the same two analysts conducted the rhetorical criticism. For each of the 13 websites, the analysts separately analyzed text, video, and the symbols therein, including word choices, phrases, and metaphors as they pertained to ethics. In addition, the WPP Code of Business Conduct was rhetorically criticized. The analysts took a receiver-centered perspective and considered the potential interpretations that the symbols would have on audiences.63 Consumers are the audience of a website64 and consumers of marcom organizations are clients and prospective clients. In addition, codes of conduct serve as a resource for employees.65 Without having knowledge of how the websites were created and with what intentions, which would suggest a producer-centric approach to analysis, the analysts reviewed the sites as an audience might, by being interested in learning more about each agency in general, and in response to the research questions specifically, by focusing their attention on ethics. Notes on individual websites were taken, then combined and analyzed as a collective unit. Through this comprehensive reading, themes were identified and used to categorize the data, as is often done in qualitative analysis.66 Throughout the findings, reference to WPP Code of Business Conduct is by formal title as well as by “Code,” and the subsidiaries’ related values are referred to as “codes” and “values.” Next, findings are presented and implications for practice and future research are discussed.


Code as Exemplary

How does the WPP Code of Business Conduct serve as moral exemplar, if at all, for marcom organizations? The Code is exemplary, meaning it might serve as an example for the industry, in two overarching ways. First, the Code suggests the importance of a corporation that acts virtuously and has global reach. Since the organization has global reach, these virtuous acts have the potential to reach broad external audiences. Second, the Code suggests the importance of providing clear and accurate communication. A code of conduct can only inform an audience to the extent that its language is clear, and can only set an example to the extent that it reaches an audience in the first place. With global, external reach (i.e., members of the industry but those not working for the agency, such as clients and prospective employees), and clearly set standards of practice, the Code has this potential. An elaboration of each theme follows.

The Code begins with a statement regarding WPP’s and its subsidiaries’ operations in “… many markets and countries throughout the world.” The Code then elaborates on the corporations “… respect for national laws and any other laws with an international reach …” As a globally connected organization, WPP and its subsidiaries have the opportunity to set an example for other marketing companies and their respective clients and vendors.

Symbols therein indicate that the organization is concerned with both internal and external audiences. References to internal agents include “board,” “businesses,” “employee,” “group,” “individuals,” “people,” “share owners,” and “WPP.” References to external agents include “clients,” “community organisations,” “company,” “society,” “suppliers,” and “third party.” The Code further provides ethical guidance for interactions with both internal and external audiences. Regarding internal members, WPP promotes “people on the basis of their qualifications and merit,” believes in a workplace that is “safe and civilized,” and protects employee data. Regarding external relationships, the Code details several points including, first and foremost as listed in bullet one, its “obligations to all who have a stake in our success including share owners, clients, staff and suppliers.” In addition, client information is kept confidential and the organization “will not give or accept bribes.” And, finally, the WPP Code acknowledges the role its agencies have on society. Regarding society, WPP “strives to make a positive contribution to society and the environment,” respects human rights, does “not knowingly create work which contains statements, suggestions or images offensive to the general public decency,” and is “committed to protecting consumer … data.”

Finally, the WPP Code of Business Conduct suggests the organization always provides clear and accurate communication. Bullet point two of the Code reads, “Information about our business shall be communicated clearly and accurately in a non-discriminatory manner and in accordance with local regulations.” By providing clear and accurate communication, various audiences are exposed to the organizations’ acts of honesty. Furthermore, the Code suggests the organization supports a duty of honesty, which will be elaborated upon below.

Code as Kantian

To what extent does the rhetoric of the WPP Code of Business Conduct represent Kantian, duty-based ethics? The Code suggests the organization has three overarching duties, two of which are reflective of Kantian duties of honesty and autonomy: a duty to act honestly and with integrity; and a duty to civility, which includes respect for autonomy. A third duty suggests an obligation to all stakeholders to succeed, which impacts the organization’s and its subsidiaries’ reputations, which subsequently impacts the integrity of the organization.

The third and last line of the opening paragraph states that WPP and its subsidiaries have a duty to maintain honesty and integrity: “We are committed to acting ethically in all aspects of our business and to maintaining the highest standards of honesty and integrity.” The first reference to honesty appears in the second bullet after the introduction, stating, “Information about our business shall be communicated clearly and accurately in a non-discriminatory manner and in accordance with local regulations.” In addition, honesty is supported by several other points including rejecting work intended to be misleading in nature, neither giving nor accepting bribes, not offering “personal inducements to secure business,” and not engaging in “conflicts of interest.”

Regarding integrity, commonly accepted definitions include the aspects of morality, honesty and wholeness. The distinctive characteristic to note, endorsed by the Code, is wholeness. Wholeness is supported by the use of “We” throughout the document, which appears twice in the first three sentences of the introduction, within 15 of the 17 proceeding bullets and a total of 17 times within the bullets. “We” is defined in the first bullet as “the officers and staff of all companies in the WPP group.” In addition, “our” is used 10 times within the bullets and once in the introduction. The symbolic use of “We” suggests that the organization is only as successful, or as ethical, as its contributing parts including all the subsidiaries and employees therein that constitute the firm.

Prominence is next given to the duty to stakeholders by appearing within the first bullet as follows: “We … recognize our obligations to all who have a stake in our success including share owners, clients, staff and suppliers.” By using the prepositional phrase, “in our success,” the reader is oriented to the obligations to both stakeholders and success. This duty is supported later on in bullet 10 in reference to reputation, which states: “We will consider the potential for clients or work to damage the Group’s reputation prior to taking them on. This includes reputation damage from association with clients that participate in activities that contribute to the abuse of human rights.” While the point first suggests WPP has a duty to uphold its reputation, in an effort to maintain success and its obligation to stakeholders, the reader also learns WPP has a duty to respect others by upholding “human rights.”

WPP’s duty to respect others is supported throughout the document. Specific attention is called to bullets three, four, five, six, seven, and eight, which emphasize civility, non-discriminatory acts, and privacy. Within these bullets, WPP states that the organization “believe[s] that a workplace should be safe,” “will not tolerate sexual harassment, discrimination or offensive behavior of any kind,” “will treat all information relating to the Group’s business, or to its clients, as confidential” and “are committed to protecting consumer, client and employee data,” which are examples suggesting how people are respected. Through these examples, the Code implies that employees, clients, and stakeholders are ends, worthy of respect and autonomy, and that WPP has a duty to treat them accordingly.

Rhetoric upholding WPP Code of Business Conduct

How, if at all, does the rhetoric on WPP companies’ websites uphold the WPP Code of Business Conduct? The Code is acknowledged explicitly and implicitly, through direct references and associated examples. An explicit reference is that of PBN Hill+Knowlton Strategies (PBN), a global public relations agency. The PBN web text reads, “We are proud to comply fully with the WPP Code of Conduct.” Likewise, These Days,67 an integrated communications agency offering a range of services from strategy to advanced analytics, has a link at the bottom of every page to “WPP Code of Business Conduct for Suppliers.” Other sites reference codes in words and phrases, such as Kantar Health68 operating with “honesty, integrity and respect for people,” but without directly referencing the WPP Code of Business Conduct. As a partner with healthcare innovators by providing communication and consulting services, the Feinstein Kean Healthcare (FKH) site states, “Day in and day out, the objectives of our clients become our objectives, as we partner with them to advance new ideas, technologies, and products.” The site content goes on to explain that those enacting the partnerships at FKH are a “team of professionals.” FKH’s opening text on the site states the organization is “the first specialty consulting firm …” “established in the earliest days …” “committed to creative value for [its] clients.” Similarly, marketing data experts KBM Group (KBMG) is a “global leader.” And public relations firm Burson-Marsteller (BM) was founded “60 years ago” and is “innovative.” This rhetoric suggests the agency’s commitment to reputation and to maintain success for stakeholders’ benefit, a value appearing in the Code, which is supported by examples provided illustrating the agency’s history and expertise.

Fig. 2. In the bottom corner of These Days’ website, a link was provided to the WPP Code of Business Conduct for Suppliers.
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Fig. 2.

In the bottom corner of These Days’ website, a link was provided to the WPP Code of Business Conduct for Suppliers.69

This duty to maintain reputation is further supported by the importance an agency places on its client relationships. Text speaking directly to the client reinforces this connotation. For example, Coley Porter Bell (Coley), a brand and design firm, describes its agency in the “About us” page as an Ogilvy and WPP agency with 35 years of “proven success” serving clients “you’ll know of” like Unilever. The text continues to speak directly to the client in the “meet our people” page of the site. After clicking the link, each employee is identified by title and an accompanying biography, which lists the individual’s credentials such as years in the industry, years at Coley, clients serviced, projects completed, and skills. The biography then answers a question along the lines of, “What does that mean to you?” Returning back to “about us” and scrolling down further to continue the conversation with the client, copy asks, “Why choose us?” Throughout the text, the client is consistently addressed by “you” and “your.”

Rhetoric on company websites supports additional duties, such as honesty, integrity, and respect for others. Located in Vancouver, Canada, National Public Relations firm’s “Values” outlines the duties listed on the company’s website and in a 12-page PDF titled “Guiding Principles.”70 These “Values” also relate to WPP duties of success for stakeholders, integrity, civility, and respect for others. Explicitly, the National values are “quality,” “respect,” integrity,” and “responsibility.” Focusing on the latter three, “respect” reads: “NATIONAL believes that there can be no lasting success without mutual respect, and promotes courtesy in the workplace.” “Integrity” reads: “NATIONAL believes that the best way to protect its reputation is to maintain a high level of integrity and professional conduct in all its daily activities.” And “responsibility” reads: “NATIONAL manages its business in a financially responsible way: its profitability is essential to its sustainability.” Therefore, National reinforces the WPP Code by providing a comprehensive representation of duties of honesty and respect with rhetorical consistency and elaboration.

National’s values depict ethical awareness and an understanding that ethics influence reputation and success. For instance, the text reads, “The Firm has strict policies and guidelines governing the conduct of its business, notably regarding confidentiality, ethics and conflicts of interest,” and “The reputation of our Firm depends on our people acting with honesty and integrity in all of their business dealings.” Furthermore,

It is the responsibility of every employee to be a steward of our Firm. The decisions we make and the behaviours we exhibit on a daily basis affect our culture, our service offering and our viability as a business. NATIONAL’s values are the compass we use to guide these decisions and behaviours.

The inclusion of this text suggests that success and reputation cannot be maintained without ethical behavior.

National’s guiding principles also suggest the agency has a duty to society. The second sentence in the foreword of the 12-page PDF by the President and Chief Executive Officer reads: “Our people are passionately committed to their profession and to working with our clients on the key business, economic and social issues of our time.” While the symbolism also supports the duty to reputation and stakeholders’ success, the concern for “social issues of our time” suggest that the organization has a wider-reaching duty to society. This claim is again supported under “Our Vision,” which is comprised of five points, the last being “to be a responsible and ethical organization that meets its financial goals and social obligations.” The “corporate responsibility policy,” also supports this duty by stating,

As the leading communications consultancy in Canada, NATIONAL makes a positive contribution to society from an economic, social and environmental perspective. We also believe that we have an important role to play in helping our clients continuously improve the social and environmental impacts of their business activities and communications programs.

The reader then learns in the second paragraph that all employees of all National offices are “required to comply” with this policy.

Similarly, Kantar Health, a global healthcare firm that offers consultation, research and communication services, sees its reputation and success as a means to positively impact society. Text on the Kantar Health website suggests the organization improves “the health and well-being of people globally.” This headline is supported by accompanying body copy:

As an industry leader in global healthcare consulting and market research, Kantar Health is working to help improve the health and well-being of people around the world. A key measure of success for our organization resides in our corporate social responsibility and sustainability initiatives.

As evidence of its corporate social responsibility (CSR) and sustainability initiatives, Kantar Health supports global charitable organizations such as UNICEF, works to reduce its carbon footprint, participates in recycling programs, and employees volunteer time and make monetary donations in local communities.

Fig. 3. This screenshot from the Kantar Health website shows how the company and its employees contribute to a variety of causes.
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Fig. 3.

This screenshot from the Kantar Health website shows how the company and its employees contribute to a variety of causes.71

WPP Companies with Duty

To what extent does the rhetoric of WPP companies’ websites represent Kantian ethics? According to the analysis of the sites, WPP companies have a duty to respect others, such as to treat consumers as ends and thus to respect their autonomy. Implicitly, the rhetoric on the agencies’ sites suggests that these ethical duties ought to be adopted into universal law.

Respect for others acknowledges the role marcom has within society and the impact these organizations have on society. For example, Kantar Health’s “About us” includes a message from the CEO, which states: “Let us show you what you can accomplish by working with Kantar Health, and together we can help make the world a better place.” Similarly, Smollan, a retail solutions agency, offers text that reads, “We exist to deliver growth for our clients, our business and our people and in doing so, to have a profound social impact.” As evidence of this, Smollan “launched the Smollan Social Impact Plan,” which links from the website to a PDF listing goals including supporting environmental organizations and reducing emissions.

Fig. 4. A screenshot of Smollan’s 2015 Social and Environmental Impact Plan.
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Fig. 4.

A screenshot of Smollan’s 2015 Social and Environmental Impact Plan.72

KBMG focuses on data analytics for enhancing marketing effectiveness. The duty to treat people as ends, versus means to an end, is depicted on several sites and, specifically, was both contradicted and supported on KBMG’s site. Text on KBMG’s site describes their work as creating “mutual value” for the client and its customers. Under “services,” data and data analysis are listed first, followed by “who we are,” which reads:

We are a data, analytics and technology integration marketing services company committed to helping our clients achieve optimized marketing results and customer relationships. As marketing data experts for over 30 years, we help companies manage data as a strategic asset. We transform data for relevant interactions with consumers and design engagement ecosystems for synchronized communications. We help the world’s best-known brands evolve along the data-driven marketing continuum for improved marketing performance, mutually valuable customer relationships and stronger competitive advantage.

This suggests that “mutual value” is really a reduction of consumers to data, and data analysis suggests consumer are really a means to an end. While success and reputation are important to WPP and KBMG, the reader gets conflicting views of the consumer’s role in the “mutual value” equation.

Yet the reader also learns that KBMG takes the sensitive treatment of consumer data seriously, by suggesting that data “can be a strategic asset in the right hands.” Presumably, KBMG is the “right hands.” In other sections of the site, the serious nature of treating data correctly is supported by “resources” including a policy on “privacy.” The policy is to maintain multi-directional “trust” with both consumers and clients. The policy reads:

Data is core to the marketing services that KBM Group provides to clients. As long established data experts, we have built our business and reputation on the understanding that the ability to use and process consumer data can only occur in an environment where we earn the trust of both the companies on whose behalf we process customer data and the individuals to whom such data relates in order to deliver mutual value to both brands and consumers.

The policy includes a measure of accountability. The policy states, “Ensuring all these guidelines are met” [three guidelines include following laws and regulations; following codes, best practices and self-regulation; and collecting, processing, and sharing data in a manner respectful to the consumer to whom such data relates] the agency employs a Chief Privacy Officer and confers with a Council for Information and Security Practices. The page includes contact information for both.

The values of accountability along with collaboration suggest that WPP companies consider the universal nature of the Codes. Collaboration suggests that all parties agree to abide by, and be held accountable to, the same standards, suggesting these codes serve as a universal law of sorts. For example, 4129Grey, a digital marketing company, calls attention to the “shared obligation” of ethics within the “Grey Global Group Inc. Code of Business Conduct:”

Each of us is responsible for knowing and understanding the policies and guidelines contained in the following pages. But that is merely the first step. … report violations … know when to ask for guidance ... if you have questions, ask them; if you have ethical concerns, raise them.

Not only is 4129Grey asking the reader to take accountability for their actions, but also affording them the means to vocalize concerns, pose questions, and engage in an active process of ethical decision making.

Fig. 5. A screenshot of 4129 Grey’s website asserting the agency’s culture of accountability and high ethical standards.
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Fig. 5.

A screenshot of 4129 Grey’s website asserting the agency’s culture of accountability and high ethical standards.73

Fig. 6. A screenshot from Grey’s Code of Business Conduct.
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Fig. 6.

A screenshot from Grey’s Code of Business Conduct.74

Similarly, Coley posts their “green” policy online and therein states, “We believe that the future condition of our environment is the joint responsibility of all of us, we believe we all have a role to play,” which they support with “ISO 14001 accreditation,” “establishing functional waste management systems internally,” and assisting clients “in turn with their own corporate responsibility objectives.” Lastly, These Days, an integrated marketing firm, not only asks what would happen if others contributed to doing what was right, they also hold suppliers accountable. At the bottom right corner of every page, the second of two links is “WPP Code of Business Conduct for Suppliers:”

We expect and require all our business partners, including suppliers, to have the same commitment to ethical behaviour and therefore ask you to confirm your agreement with our Code of Conduct (in the first column) as amended where necessary for non-WPP entities (in the second column).

The subsequent table then includes WPP codes in the left-hand column and amendments on the right. Most amendments read entirely or initially, “You confirm that you have equivalent policies in your organisation.”

Fig. 7. A screenshot of Coley Porter Bell’s green policy.
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Fig. 7.

A screenshot of Coley Porter Bell’s green policy.75

The rhetoric on these sites, as illustrated by these examples, suggests that codes are only successful when adopted and consistently adhered to by all parties involved. Beyond the agency adopting these values, others such as clients and vendors must also adopt these values and These Days, for example, ensures this adoption will take place by asking business partners to confirm their acceptance of the codes. These examples suggest that WPP subsidiaries rely on a Kantian approach to ethical decision making. However, as noted earlier, the duty to treat people as ends was both supported and contradicted by statements on the KBMG site. Other contradictions arose.

A Critique and Contradictions

According to their site, Kantar Health operates with “honesty, integrity and respect for people,” and supports these ethical claims by providing examples of work, by linking their values to the WPP Code, and by consistently mentioning these values throughout the website. Kantar Health is an example of a site that provides clear and detailed statements, which suggest these ethical duties are upheld. Other sites, however, provided a shallow delivery of concepts, vague examples, if any, hyperbole, and contradictions.

Within the “Careers” page, FKH text reads “We are a team of professionals … We are:” “professional,” “respectful,” “open/honest/direct,” “ethical,” to name a few, which suggests they are committed to a set of values and reinforce these values by recruiting and hiring like-minded individuals. The list of values is impressive—such as the claim that the company is “ethical,” but fails to define this concept and inform the reader as to what these words mean to the company in terms of the work they do. Therefore, this text serves as little more than vague language that offers no further explanation or examples to support the meaning of these values.

Set-Live is an agency that designs physical spaces to enhance marketing environments. The Set-Live “Thinking” page has images with superimposed text. Each image is a click-through to a case study of both images and text. Superimposed text that stands out initially as ethics-related includes “your audience values your transparency and honesty,” “your audience wants to feel loved, wherever they are,” “your audience wants beautiful solutions to ethical problems,” and “different discipline, different approach.” Only the first case, however, elaborates on the values introduced, “transparency and honesty.” Yet they do so by providing a case from another corporation. Upon further navigation through the site, the audience learns that the corporation is not a client of Set-Live nor related to the agency’s services of sponsorships, film and video, product launches, or live events. The case is about AB Sugar and the debate around sugar, such as contributing to diabetes and obesity. Set-Live calls attention to the company’s “refreshing honesty” and gives “kudos to AB Sugar for having the courage to launch this campaign, despite the risk that it may lose them some consumers.” The relationship this “refreshing honesty” has with Set-Live and what it means for a client should they choose to work with Set-Live is not explained.

Fig. 8. An image from Set-Live’s website suggests the agency’s value of transparency and honesty in the work that it does.
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Fig. 8.

An image from Set-Live’s website suggests the agency’s value of transparency and honesty in the work that it does.76

Fig. 9. An image from Set-Live’s website suggests how the agency is concerned about engaging and solving ethical problems.
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Fig. 9.

An image from Set-Live’s website suggests how the agency is concerned about engaging and solving ethical problems.77

In response to the research question, to what extent does the rhetoric of WPP companies’ websites represent Kantian ethics, the findings suggest that WPP subsidiaries have a duty to respect others and to uphold ethical action as universal law. Two additional contractions to these duties should be noted. First, Shift Communications, a purpose-driven branding company, presents a rhetorically sophisticated approach, in that text on the site consistently and repeatedly upholds a singular idea: successful businesses need purpose. While needing purpose implies a greater good, or altruistic motives, there are contradictions, primarily concerning respect, and the treatment of people as ends instead of means. Shift’s ethical symbols suggest that changing business practices to purpose-driven and transparent practices is necessary to keep up with and respond to consumer demands. Business is more than making a profit, the site’s text states. Thereafter, the text reads that by making this shift in business practices, you attract apostles and evangelists. This implies that people are serving the needs of business. In other words, a business will be more profitable when it attracts more apostles who help to spread its brand message to others. Text reads, “Today people want to interact with companies whose values they buy into” and these are the organizations that “flourish” and see “extraordinary results.” Extraordinary results are presumably profits. Furthermore, if people have to “buy into” these values, they’re being sold to, persuaded, thus suggesting that people are still consumers seen as a means to a business’s success.

Second, analysis also revealed that rhetoric intended to depict ethical behavior instead often depicted legal behavior. For example, “PBN Hill+Knowlton Strategies is respected for its highly ethical business and professional practices. Our track record of always operating according to the highest international standards in every market … is a company legacy and trademark.” While the company claims to be “respected for its highly ethical business and professional practices” the concepts are vague and lack support other than suggesting an ethical business is one that follows international standards, whatever those might be.

And while the concept of operating according to standards is vague at best, soon it’s suggested that following these “standards” is unfavorable. In a video with FKH’s CEO and Chairman of Strategic Initiatives, his comments suggest that the healthcare patient (i.e., the target audience of FKH’s strategic communication efforts) could use helpful information in making healthcare decisions, but that healthcare regulations are getting in the way of FKH fulfilling this role:

… if you look at regulators, they’re trying to control that traffic and the connection between patient, drug company, etc. at a time when those connections could be very helpful to the patient. Traffic is sort of slowing, or going in uncertain directions and the traffic signals aren’t working properly because there’s not the right guidance for these companies to know how to act.

The CEO is presenting a contradictory argument by first saying that the regulators are trying to “control” the traffic, and insinuating that control is preventing communication, which would be helpful to patients. At the same time, he says that the “traffic signals aren’t working,” implying that there is a lack of control, and that this too is disagreeable. Within the organization’s “philosophy” section, the premise that regulations are restrictive or creates “pitfalls” is further supported. The text reads,

FKH likes the hardest challenges. We believe that innovation without best execution will not succeed, so we help our clients to grapple with a dramatically changing environment, adjust to new regulatory demands, find new constituencies for support, and avoid the myriad pitfalls inherent in a highly-regulated field.

Due to the confusing nature of these statements, and to clarify the agency’s ethical stance, it would be helpful to the reader to know the extent to which these regulations contribute to or circumvent the pitfalls, the extent to which regulations are upheld, and how FKH’s ethical values provide additional support for navigating the changing environment.


Moral exemplars that represent normative standards of behavior, from which other organizations and practitioners can learn, should be revealed and examined. Ethical challenges in marcom abound. Marcom practices include those of advertising and public relations organizations, and marcom ethics occur in response to new and emerging communication practices and to the many, and often competing, loyalties the practitioners of these organizations have. When faced with these complex challenges, employees of these organizations as well as the clients they represent look to their respective agencies for guidance. Therefore, this rhetorical criticism asked, to what extent does the WPP Code of Business Conduct and related language on WPP companies’ websites represent Kantian ethics, or a duty to ethics? WPP’s Code and subsidiaries’ website content suggests the conglomerate has a duty to act with honesty and integrity, and a duty to respect others, and that these ethical duties ought to be adopted by its employees as well as business partners, which would include clients, vendors and media partners.

This study also asked, how does the WPP Code of Business Conduct, if at all, serve as a moral exemplar for marcom organizations; and how does the rhetoric on WPP companies’ websites uphold WPP Code of Business Conduct, if at all? WPP, with its 356 companies worldwide, has the potential to set an example for the marcom industry. According to the Code, the organization has global reach, and engages in various communicative acts reaching internal and external audiences that are intended to be both clear and accurate. Furthermore, WPP subsidiary companies, those restating the values of the Code, suggest how the WPP Code can serve as a model of excellence. These companies, on their respective websites, include the explicit language as well as the implicit meaning of the Code, thus modelling WPP as well as suggesting that these values are important to uphold. For example, the WPP organization National consistently and explicitly presents ethical values on its website and in a supplementary PDF, by listing and defining the values of “quality,” “respect,” “integrity,” and “responsibility,” to name a few. These Days not only provides ethical values that support the WPP Code, but also states on its site that the organization requires suppliers to commit to the same ethical behavior by providing evidence that the agency has equivalent policies to the Code. Superseding duties to act with honesty and integrity, the Code begins by stating the organization has a duty to stakeholders, to maintaining success and reputation, and that WPP subsidiaries share this duty, which isn’t entirely surprising. Marcom agencies are for-profit, service providers. To be profitable, agencies must persuade audiences to buy a client’s product, as well as persuade a perspective client to buy into their services and expertise. Sharing this duty, to maintain a good reputation, is not only the right thing to do, it’s simply good for business.

WPP—an international holding company that requires ethical training, with ethical values governing 356 agencies, many of which are international—is a moral exemplary candidate. The Code depicts a certain universal law, which is represented by agencies such as Grey Global Group Inc. and These Days asking vendors to comply with the espoused values of honesty and respect. Kant’s categorical imperative asks one to imagine what would happen if everyone adopted the same moral imperative. In the case of WPP, the Code asks WPP’s subsidiaries and business partners to imagine what would happen if they adopted honesty and respect for others. Marcom agencies provide a service and therefore respond to multiple interests from clients, consumers and vendors. The agencies’ multiple duties, which at times conflict, necessitate respect as essential to the morality of the industry, not to mention its success and sustainability. Therefore, the WPP Code might just be an exemplary code of ethics needed to respond to the emerging practices of marcom with ethical implications by providing a categorical imperative, such as respect, that remains unchanged.

Yet no company, even one espousing the duty to honesty and respect is without flaws. Codes of ethical conduct are only one step in the ethical decision-making process, albeit an important one. Ethical codes of conduct serve as guidance, by suggesting to internal and external audiences what an organization values and ideally how ethical business practices should be enacted. Behavior can still occur in opposition to these values. While the rhetoric on WPP websites suggest WPP organizations respect others, have a duty to act honestly and with integrity, several of the sites were merely an ethical façade offering little more than unsubstantiated ethical jargon. Set-Live presents “thoughts” relative to ethical problem solving. But instead of telling audiences how they solve ethical problems, Set-Live commended an unrelated business for “honestly” debating a health issue, which simply presents an appearance of ethics. To appear concerned and invested, but provide little to no information or examples relative to the organization and its services, is to serve merely as a rhetorical device without intention – ethical, persuasive or otherwise. Ethical codes are only as effective as they are clear. Conversely, vague, ambiguous guidelines only make it easier to behave unethically. Therefore, marcom agencies must consider not only the values they present to internal and external audience, but the extent to which these values are defined, and examples are provided, which provide clarity as well as suggest how the agency enacts and upholds these values, which will help others model ethical behavior.

Limitations, Future Research & Conclusion

The current study utilized two of Schein’s78 three levels of analysis: an organizational artifact and the values therein. While this might be seen as a limitation, the analysis of the artifact and espoused values provided depth for answering the research questions at hand. However, observing the organizational culture of WPP subsidiaries would only enrich the findings presented here to suggest how codes might enable or constrain ethical action. Therefore, future research should identify organizations, such as those within WPP holding or others espousing similar ethical codes and values, to examine ethical behavior enacted and what role these codes and values serve in the process. A second limitation and area for future research is in regard to the receiver-centered perspective of analysis. While an appropriate perspective for rhetorical criticism, future research might request participation from employees and clients, as actual recipients of codes and values, to examine their perspectives, applications and critiques of the codes. Similarly, this article provided one interpretation of the artifacts. As communications scholar Sonja Foss suggested, a critic can only know an artifact through interpretation,79 and in this process, one cannot be objective or removed from the data, because one approaches the data with a particular view and task. In the current article, the task was to explain the symbols of ethics and the extent to which the Code might serve as an example for others. Therefore, to understand the codes from other perspectives, additional research is needed.

While imperfect, the WPP Code of Business Conduct details 17 espoused values that encourage ethical behavior, supported by an overarching duty to maintain “the highest standards of honesty and integrity.” Codes of ethics work only to the extent they are known and to which members are held accountable. For example, These Days asks clients to acknowledge and agree to the ethical principles that guide decision making. Similarly, other marcom organizations might ask employees and clients to sign a code of conduct encouraging them to consider ethical principles when confronted with an ethical dilemma. For WPP organizations specifically, to show commitment to moral practices, at the very least, WPP organization websites should link to the Code versus providing vague or little to no reference to ethical values. The values and behaviors promised in the Code should be evident in relevant web site sections such as “Our Work,” “About Us,” “Our Expertise,” and similar categories. We also suggest that corporate codes of ethics should be apparent and infused in an organization’s promotional and other informational materials.

While the analysts examined websites from an ethical perspective, the vaguely associated references on some sites might hold little meaning for audiences, such as prospective employees and clients, who are unfamiliar with WPP, the Code, or ethics in general. Future research, from the employees’ or clients’ perspectives, might examine the extent to which this suggestion is supported. Finally, as the WPP Code states, the organization operates in many countries. The organizations that conduct business in those markets, and the 356 organizations in total, have an opportunity to set ethical standards for the industry by espousing values supported by the Code on their respective websites, thus truly serving as moral exemplars with global reach and impact.

Erin E. Schauster

Assistant Professor, University of Colorado Boulder, Erin Schauster holds a doctorate from the University of Missouri School of Journalism. Schauster’s research examines media ethics with a focus on ethical decision making in advertising impacted by organizational culture. Her research also examines the changing organizational structures and practices of advertising and public relations industries and the implications these changes have for higher education and normative decision making.

Tara Walker

Tara Walker is a doctoral student at University of Colorado Boulder. Walker is interested in the creation and dissemination of persuasive messages in mass media and their effect on perceptions of gender, sexuality and race. Walker has published in literary magazines including Magnolia: A Journal of Socially Engaged Women’s Literature and The Columbia Poetry Review, and presented at conferences including the Conference on Community Writing and the Association for Education in Journalism and Mass Communication (AEJMC).

Margaret Duffy

Margaret Duffy is a professor at University of Missouri School of Journalism. Her research focuses on new and interactive media, especially with regard to advertising and the news. Her recent research involves pass-along political emails, and perceptions of advertising ethics.

Appendix A. WPP Companies Analyzed*
Blast Radius (Blast) operates as a global boutique with offices in 12 cities around the world. Blast specializes in digital marketing, using technology in the service of creativity to build “brands that are natively digital, mobile and social.”
Burson-Marsteller (BM), established in 1953, is a leading global public relations and communications firm, and member of the Young & Rubicam Group. The firm provides a full range of integrated strategic communications services including public affairs, reputation and crisis management, and digital strategies.
Coley Porter Bell (Coley) is an Ogilvy & Mather agency specializing in brand design with 35 years of experience. Coley utilizes neuroscience to offer a unique Visual Planning™ process, which is a proprietary approach to strategic and design thinking, by understanding how people make and rationalize decisions.
KBM Group (KBMG) has operated for over 30 years in knowledge-based marketing, offering services of data analytics, data management and data optimization. KBMG’s parent company, Wunderman, is part of the Young & Rubicam Group.
MJM provides corporate meetings and training programs on every continent for a variety of industries including health care, consumer products, finance, automotive, and nonprofit.
NATIONAL Public Relations (National) has offices across Canada, Europe and the United States. Bringing together research, strategy, and creativity from a diverse network, the agency focuses on team building, and providing clients with bold thinking.
SET Live is a global marketing agency that specializes in communicating to live audiences. The agency works with brands such as Google, YouTube, Bentley and Heineken to “activate sponsorships, launch products and communicate services” to audiences.
Smollan opened its doors in 1931 as a regional South African sales agency and grew to an international retail solutions company. Smollan is “the pivot point where the retailer, brand owner and shopper intercept,” managing every aspect of brand strategy and delivering exceptional shopper experiences.
These Days, founded in 2001, is an integrated, multidisciplinary communication agency. These Days delivers services such as strategy, creation, production, media and analytics, as well as several distinctive tools for CRM, retail, social media, advanced analytics and campaign management.
4129Grey is a full-service advertising agency operating within the Grey network. 4129Grey embraces an integrated communication approach to impact popular culture and amplify that impact across many channels including national headlines, the evening news and everyday conversation.
Kantar Health is a global healthcare consulting and research firm. Kantar Health offers services of “consulting and research to communicate the value and potential for products and services that fall under healthcare regulation and legislation.”
Feinstein Kean Healthcare (FKH) was established in 1987. FKH provides communication and consulting services to support healthcare innovators by providing laboratory research, diagnostics and pharmaceutical innovation and healthcare delivery.
PBN Hill+Knowlton Strategies (PBN) is a global public relations and integrated communications agency offering three services: consulting, creating, and connecting. Supported by data and insights, the agency focuses on creating engaging content across owned, earned, shared, and paid channels.
Shift was* a purpose-driven branding company that helped organizations uncover their true purpose and create brands that people loved to work for, buy from, deal with and invest in. *Shift closed in 2016.

*Organizational changes to the WPP companies analyzed and content changes to their respective websites have occurred since this study was first conducted. These changes were discovered during the editing process in preparation for publication and are noted in the findings and in Appendix A. Please note that additional changes might have occurred.

Appendix B. WPP Code of Business Conduct

WPP and its companies operate in many markets and countries throughout the world. In all instances, we respect national laws and any other laws with an international reach, such as the UK Bribery Act and the US Foreign Corrupt Practices Act, where relevant, and industry codes of conduct. We are committed to acting ethically in all aspects of our business and to maintaining the highest standards of honesty and integrity.

  • • We, the officers and staff of all companies in the WPP group (“the Group”), recognise our obligations to all who have a stake in our success including share owners, clients, staff and suppliers;

  • • Information about our business shall be communicated clearly and accurately in a non-discriminatory manner and in accordance with local regulations;

  • • We select and promote our people on the basis of their qualifications and merit, without discrimination or concern for race, religion, national origin, colour, sex, sexual orientation, gender identity or expression, age or disability;

  • • We believe that a workplace should be safe and civilised; we will not tolerate sexual harassment, discrimination or offensive behaviour of any kind, which includes the persistent demeaning of individuals through words or actions, the display or distribution of offensive material, or the use or possession of weapons on WPP or client premises;

  • • We will not tolerate the use, possession or distribution of illegal drugs, or our people reporting for work under the influence of drugs or alcohol;

  • • We will treat all information relating to the Group’s business, or to its clients, as confidential. In particular, “insider trading” is expressly prohibited and confidential information must not be used for personal gain;

  • • We are committed to protecting consumer, client and employee data in accordance with national laws and industry codes;

  • • We will not knowingly create work which contains statements, suggestions or images offensive to general public decency and will give appropriate consideration to the impact of our work on minority segments of the population, whether that minority be by race, religion, national origin, colour, sex, sexual orientation, gender identity or expression, age or disability;

  • • We will not undertake work which is intended or designed to mislead, including in relation to social, environmental and human rights issues;

  • • We will consider the potential for clients or work to damage the Group’s reputation prior to taking them on. This includes reputational damage from association with clients that participate in activities that contribute to the abuse of human rights;

  • • We will not for personal or family gain directly or indirectly engage in any activity which competes with companies within the Group or with our obligations to any such company;

  • • We will not give, offer or accept bribes, whether in cash or otherwise, to or from any third party, including but not restricted to government officials, clients and brokers or their representatives. We will collectively ensure that all staff understand this policy through training, communication and by example;

  • • We will not offer any items of personal inducement to secure business. This is not intended to prohibit appropriate entertainment or the making of occasional gifts of minor value unless the client has a policy which restricts this;

  • • We will not accept for our personal benefit goods or services of more than nominal value from suppliers, potential suppliers or other third parties;

  • • We will not have any personal or family conflicts of interest within our businesses or with our suppliers or other third parties with whom we do business;

  • • No corporate contributions of any kind, including the provision of services or materials for less than the market value, may be made to politicians, political parties or action committees, without the prior written approval of the WPP board; and

  • • We will continue to strive to make a positive contribution to society and the environment by: maintaining high standards of marketing ethics; respecting human rights; respecting the environment; supporting community organisations; supporting employee development; and managing significant corporate responsibility risks in our supply chain. Our Corporate Responsibility Policy provides more detail about our commitments in these areas.

This article does not contain any studies with human participants or animals performed by any of the authors.


1. Beth Cotter, “Cool to be part of something big - WPP Group,” How I Put My ADHD to Good Use, February 1, 2011, accessed May 24, 2018,

2. Ryan Beene, “VW Puts U.S. Ads on Hold Amid Emissions Scandal,” Advertising Age, September 27, 2015, accessed May 21, 2018,

3. Tim Peterson, “Brands to Publishers: Let Us Check Your Viewability Rates or We’ll Stop Buying Ads,” Advertising Age, May 26, 2015, accessed May 21, 2018,

4. Lili Levi, “A ‘Faustian Pact’? Native Advertising and the Future of the Press,” Arizona Law Review 57, no. 3 (2015): 647–711.

5. Keith J. Kelly, “FTC Outlines Native Advertising Rules for Publishers,” New York Post, December 30, 2015, accessed May 21, 2018,

6. Patrick Lee Plaisance, Virtue in Media: The Moral Psychology of Excellence in News and Public Relations (New York and London: Routledge, 2015); Minette E. Drumwright and Patrick E. Murphy, “How Advertising Practitioners View Ethics: Moral Muteness, Moral Myopia, and Moral Imagination,” Journal of Advertising 33, no. 2 (2004): 7–24; and Erin Schauster, “The Relationship between Organizational Leaders and Advertising Ethics: An Organizational Ethnography,” Journal of Media Ethics 30, no. 3 (2015): 150–67.

7. William O’Barr, “Ethics and Advertising,” Advertising & Society Review 8, no. 3 (2007).

8. Lee Wilkins, “Advertising Ethics: Applying Theory to Core Issues in Defining Practical Excellence,” in Persuasion Ethics Today, ed. Margaret Duffy and Esther Thorson (New York: Routledge, 2016), 29.

9. Marlene Neill, “Accredited vs. Non-Accredited: How Accreditation Impacts Perceptions and Readiness to Provide Ethics Counsel,” Public Relations Review 42, no. 5 (August 2016).

10. Dennis L. Wilcox and Glen T. Cameron, Public Relations: Strategies and Tactics (New York: Allyn and Bacon, 2007); and Philip Seib and Kathy Fitzpatrick, Public Relations Ethics (Belmont, CA: Wadsworth, 2006).

11. Plaisance, Virtue in Media; Shannon Bowen, “Organizational Factors Encouraging Ethical Decision Making: An Exploration into the Case of an Exemplar,” Journal of Business Ethics 52, no. 4 (July 2004): 311–24; and Hongsik Yu, Jingren Si, and Jaehee Cho, “Effects of Emotional Exemplars in Responsibility Attribution-Framed News Reports on Perception and Evaluations of Social Issues,” Asian Journal Of Communication 25, no. 5 (2015): 525–45.

12. Saviour L. S. Nwachukwu and Scott J. Vitell Jr., “The Influence of Corporate Culture on Managerial Ethical Judgments,” Journal of Business Ethics 16, no. 8 (June 1997): 757–76.

13. Seow Ting Lee and I-Huei Cheng, “Ethics Management in Public Relations: Practitioner Conceptualizations of Ethical Leadership, Knowledge, Training and Compliance,” Journal of Mass Media Ethics 27, no. 2 (2012): 80–96.

14. Angela M. Lee, Renita Coleman, and Logan Molyneux, “From Thinking to Doing: Effects of Different Social Norms on Ethical Behaivor in Journalism,” Journal of Media Ethics 31, no. 2 (2016): 81.

15. “How We Behave,” WPP,

16. K. McIlwain, personal communication, September 30, 2014.

17. Ibid.

18. Marlene S. Neill and Minette E. Drumwright, “PR Professionals as Organizational Conscience,” Journal of Mass Media Ethics 27, no. 4 (2012): 220–34.

19. Peggy H. Cunningham, “Ethics of Advertising: Oxymoron or Good Business Practice?” in The Advertising Business, ed. John Philip Jones (Thousand Oaks, CA: Sage, 1999), 499–515.

20. “Standards of Practice of the American Association of Advertising Agencies,” American Association of Advertising Agencies, last modified September 18, 1990,

21. “PRSA Code of Ethics: Preamble,” Public Relations Society of America,

22. Erin Schauster and Marlene Neill, “Have the Ethics Changed? An Examination of Ethics in Advertising and Public Relations Agencies,” Journal of Media Ethics 32, no. 1 (2017): 45–60

23. Richard L. Johannesen, Kathleen S. Valde, and Karen E. Whedbee, Ethics in Human Communication (Prospect Heights, IL: Waveland Press, 1990).

24. Richard M. Weaver, “Language Is Sermonic,” in Contemporary Theories of Rhetoric, ed. Richard L. Johannesen (New York: Harper and Row, 1971), 175.

25. Gerald L. Pepper, Communicating in Organizations: A Cultural Approach (New York: McGraw-Hill, 1995).

26. George Cheney and George N. Dionisopoulos, “Public Relations? No, Relations with Publics: A Rhetorical-Organizational Approach to Contemporary Corporate Communications,” in Public Relations Theory, ed. Carl H. Botan and Vincent Hazleton (Hillsdale, NJ: Lawrence Erlbaum Associates, 1989), 135–57.; and Michael E. Pacanowsky and Nick O’Donnell-Trujillo, “Organizational Communication as Cultural Performance,” Communication Monographs 50, no. 2 (1983): 126–47.

27. Jeffrey Pfeffer, “Management as Symbolic Action: The Creation and Maintenance of Organizational Paradigms,” in Research in Organizational Behavior, ed. Larry L. Cummings and Barry M. Straw, vol. 3 (Greenwich, CT: JAI Press, 1981), 1–52.; and J. Michael Sproule, “The New Managerial Rhetoric and the Old Criticism,” Quarterly Journal of Speech 74, no. 4 (1988): 468–86.

28. Pfeffer, “Management as Symbolic Action.”

29. Joann Keyton, Communication and Organizational Culture: A Key to Understanding Work Experiences (Thousand Oaks, CA: Sage, 2005); Edgar H. Schein, “Organizational Culture,” American Psychologist 45, no. 2 (February 1990): 109–19; and Edgar H. Schein, Organizational Culture and Leadership, 4th ed. (San Francisco, CA: Jossey-Bass, 2010).

30. Edgar H. Schein, Organizational Culture and Leadership, 2nd ed. (San Francisco, CA: Jossey-Bass, 1992).

31. Keyton, Communication & Organizational Culture; and Schein, “Organizational Culture,” American Psychologist 45, no. 2 (1990).

32. Matthew W. Seeger, Ethics and Organizational Communication (Cresskill, New Jersey: Hampton Press Inc., 1997) 191.

33. Ibid.

34. The 4A’s is an American advertising agency trade association also known as the American Association of Advertising Agencies.

35. Mark John Somers, “Ethical Codes of Conduct and Organizational Context: A Study of the Relationship between Codes of Conduct, Employee Behavior and Organizational Values,” Journal of Business Ethics 30, no. 2 (March 2001): 185–95.

36. Robert L. Heath, Strategic Issues Management: Organizations and Public Policy Challenges (Hillsdale, NJ: Lawrence Erlbaum Associates, 1997).

37. Chris Roberts, “The Minimum and Maximums of Professional Ethics Codes,” in Persuasion Ethics Today, ed. Margaret Duffy and Esther Thorson (New York: Routledge, 2016), 260–79.

38. “Code of Ethics and Business Conduct,” Edelman,

39. Philip Meyer, Ethical Journalism (New York: Longman, 1987).

40. Roberts, “The Minimum and Maximums of Ethical Codes.”

41. Johannesen, et al., Ethics in Human Communication.

42. Richard E. Crable, “Ethical Codes, Accountability, and Argumentation,” Quarterly Journal of Speech 64, no. 1 (1978): 23–32.

43. Roberts, “The Minimum and Maximums of Ethical Codes.”

44. Anne Colby and William Damon, Some Do Care: Contemporary Lives of Moral Commitment (New York, NY: Free Press, 1992).

45. Bowen, “Organizational Factors Encouraging Ethical Decision Making.”

46. Ibid., 321.

47. Russ Shafer-Landau, The Fundamentals of Ethics (New York: Oxford University Press, 2010).

48. Thomas E. Hill Jr., “Kantian Normative Ethics,” in The Oxford Handbook of Ethical Theory, ed. David Copp (New York: Oxford University Press, 2007), 480–514.

49. Patrick Lee Plaisance, “Transparency: An Assessment of the Kantian Roots of a Key Element in Media Ethics Practice,” Journal of Mass Media Ethics 22, no. 2/3 (2007), 188.

50. Ibid.

51. Ibid.

52. AEJMC, “Examining the Practice and Ethical Implications of Native Advertising for Public Relations and Advertising,” Paper presented at the Association for Education in Journalism and Mass Communication, San Francisco, 2015; and Alexandra Bruell, “Transparency Debate Rages at 4A’s,” Advertising Age, March 16, 2013, accessed May 21, 2018,

53. Lynne M. Baab, “Portraits of the Future Church: A Rhetorical Analysis of Congregational Websites,” Journal of Communication & Religion 31, no. 2 (November 2008): 143–81; and Jun Young and Kirsten A. Foot, “Corporate E-Cruiting: The Construction of Work in Fortune 500 Recruiting Websites,” Journal of Computer-Mediated Communication 11, no. 1 (November 2005): 44–71.

54. K. C. Elliott, “A Cluster Analysis of Enron’s Code of Ethics,” in Rhetorical Criticism: Exploration & Practice, ed. Sonja K. Foss (Prospect Heights, IL: Waveland Press, Inc., 1996), 94–100..

55. Michael Rosen, “Breakfast at Spiro’s: Dramaturgy and Dominance,” Journal of Management 11, no. 2 (July 1985): 31–48.

56. Foss, Rhetorical Criticism.

57. Bernard L. Brock, Robert Lee Scott, and James W. Chesebro, Methods of Rhetorical Criticism: A Twentieth-Century Perspective, 3rd ed. (Wayne State University Press, 1990), 14; and Robert L. Heath, “The Rhetorical Tradition: Wrangle in the Marketplace,” in Rhetorical and Critical Approaches to Public Relations II, ed. Robert L. Heath, Elizabeth L. Toth, and Damion Waymer (New York: Routledge, 2009).

58. Rosen, “Breakfast at Spiro’s.”

59. John December, “Units of Analysis for Internet Communication,” Journal of Communication 1, no. 4 (March 1996); and Young and Foot, “Corporate E-Cruiting.”

60. Website URLs were collected from

61. Only English language sites were included in analysis. In the event a site did not include an English version, the next site on the WPP alphabetized list was chosen.

62. Judy H. Gray and Iain L. Densten, “Integrating Quantitative and Qualitative Analysis Using Latent and Manifest Variables,” Quality and Quantity 32, no. 4 (November 1998): 419–31.

63. Craig Lee Engstrom, “Rhetorical Criticism as a Method for Examining Cultural Pressures on Organizational Form,” Qualitative Research in Organizations and Management: An International Journal 5, no. 3 (2010): 259–79.

64. Yuhmiin Chang, “An Exploration of the Standardization of Targeting Strategies and the Use of Promotional Disciplines on the Web: A Cross-National Study,” Journal of Marketing Communications 15, no. 5 (2009): 327–43.

65. Johannesen, et al., Ethics in Human Communication; and Roberts, “The Minimum and Maximums of Ethical Codes.”

66. Amanda Coffey and Paul Atkinson, Making Sense of Qualitative Data: Complementary Research Strategies (Thousand Oaks, CA: Sage, 1996).

67. Since this paper was accepted for publication, These Days changed their name to Wunderman Antwerp.

68. Since this paper was accepted for publication, the Kantar Health website has undergone content changes.

69. “Work,” These Days,

70. Since this paper was accepted for publication, the content “Values” and document “Guiding Principles” are no longer linked to the National website.

72. “The Smollan Social Impact Plan,” Smollan,

73. “Culture,” 4129 Grey,

74. “Code of Business Conduct,” Grey Global Group Inc.,

75. “Work,” Coley Porter Bell,

76. “Thinking,” Set-Live, The authors retrieved this image in 2016.

77. Ibid.

78. Schein, “Organizational Culture,” American Psychologist 45, no. 2 (1990).

79. Foss, Rhetorical Criticism.

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