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Development of Norms Through Compliance Disclosure

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Abstract

This article introduces compliance disclosure regimes to business ethics research. Compliance disclosure is a relatively recent regulatory technique whereby companies are obliged to disclose the extent to which they comply with codes, ‘best practice standards’ or other extra-legal texts containing norms or prospective norms. Such ‘compliance disclosure’ obligations are often presented as flexible regulatory alternatives to substantive, command-and-control regulation. However, based on a report on experiences of existing compliance disclosure obligations, this article will identify major weaknesses that prevent them from becoming effective mechanisms to discipline a certain type of behaviour. It will be argued that regulatory recourse to compliance disclosure obligations is nonetheless worthwhile if we view them as mechanisms that can initiate a dialogue about norm interpretation, application and norm desirability. From this perspective, compliance disclosure obligations serve less to discipline companies by making corporate practices transparent, and more to trigger a process of norm development, in which the law, companies and their stakeholders interact. This article provides an illustration of how mandatory disclosure, if it is restricted to a unilateral communication process, may produce no effective results (or even prove counterproductive), whilst highlighting the alternative potential of disclosure as an initiator of dialogue, supported by laws, geared towards the development and refinement of norms applicable to business in a global context and the values they promote.

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Notes

  1. In this article I speak of ‘norm proposal’ when a text defining an ‘ought to’ aspires to become a norm. The existence of a ‘norm’ is assumed when many persons regularly behave in a certain way, and this type of behaviour is approved, and deviant behaviour meets with disapproval from the community to which the person belongs (see Axelrod 1986, p. 1096 et seq.; Pettit 1990, p. 728 et seq.; Donaldson and Dunfee 1994, p. 263 et seq. for different approaches leading to similar definitions of the term “norm”).

  2. In this article I use the term ‘extra-legal’ to depict any norm or norm proposal that cannot be situated within the traditional hierarchy of legal norms issued by a state lawmaker or developed through jurisprudence, where the higher norms legitimize the lower ones with national constitutions and ratified international treaties ranging at the top of this hierarchy. However, by using the term ‘extra-legal’, I do not intend to take a stance on the ‘law without state’ issue relating to the circumstances under which extra-legal norms could be viewed as law (see Parker 2008 for a discussion of this). Nor do I exclude the possibility that a state lawmaker can propose a norm to which a law or a contract makes reference (for the use of the term ‘extra-legal’ applied to corporate governance codes, see also Goulding et al. 2005).

  3. Any person who has access to and is interested in the disclosed information can qualify as a ‘disclosure addressee’—an economic interest is not required. This term is thus wider than the term ‘user’ deployed by Fung et al. (2007), which refers to a person who uses disclosed information to make decisions. If, as can be expected, anybody affected by norm-relevant behaviour is potentially interested in the information that a compliance statement may convey, then disclosure addressees and persons affected by norm-relevant behaviour are (potentially) congruent.

  4. Listing Rule 9.8.6 (6) (FSA 2009) reads: “In the case of a listed company incorporated in the United Kingdom, the following additional items must be included in its annual financial report: […] a statement as to whether the listed company has: (a) complied throughout the accounting period with all relevant provisions set out in Section 1 of the Combined Code; or (b) not complied throughout the accounting period with all relevant provisions set out in Section 1 of the Combined Code and if so, setting out: (i) those provisions, if any, it has not complied with; (ii) in the case of provisions whose requirements are of a continuing nature, the period within which, if any, it did not comply with some or all of those provisions; and (iii) the company’s reasons for non-compliance […].” Section 161 of the German Joint Stock Corporation Act reads (convenience translation): “The executive board and supervisory board of exchange-listed companies shall declare once a year that the recommendations of the ‘Government Commission on the German Corporate Governance Code’ published by the Federal Ministry of Justice in the official section of the electronic Federal Gazette have been and are being complied with, or declare which of the Code’s recommendations are not being applied. The declaration shall be made permanently accessible to stockholders.”

  5. In the European Union, the UK listing rules provide for the furthest reaching mandate of statutory auditors in this respect (see FSA 2009, Listing Rule 9.8.10 (2)). Elsewhere, auditors do not verify more than the proper respect of procedures pertaining to the issuance of the compliance statement; see Fasterling and Duhamel (2009, p. 145 et seq.), Risk Metrics (2009, p. 69 et seq.).

  6. To illustrate the point, MacNeil and Li (2006, p. 488) report that while 47% of their sample companies considered themselves fully compliant with the Combined Code, an independent consulting firm came to a different conclusion and estimated the rate of full compliance to be 34% for the same sample.

  7. The only remedy against this problem would be to adopt far-reaching causality presumptions in favour of plaintiffs that consider any kind of information relevant for stock market prices. Jurisprudence in the United States had introduced such presumptions on the basis of the so-called ‘fraud on the market theory’, but when they faced extensive litigation abuse (see Rodriguez 2000), the US Congress and Supreme Court placed limits on the litigation practice that based claims on the ‘fraud on the market’ jurisprudence (see Fasterling and Duhamel 2009, p. 151 for references to relevant case history).

  8. The dialogue is ‘public’ if the compliance disclosure and disclosure addressee responses are accessible to anyone. It could be questioned whether the fundamental procedural precepts of dialogue are observed if one of the dialoguing parties is coerced to speak, and in the context of this article one might ask whether it is adequate that mandatory law prompts the dialogue. We have seen, however, that under a compliance disclosure regime mandatory law does not specifically mandate dialogue, but only the disclosure of compliance with a proposed norm. Dialogue remains optional and depends on the motivation of disclosers and disclosure addressees to interact with each other.

  9. In the case of ‘comply or explain’ obligations in the EU, varying non-state or public–private bodies have proposed norms that subsequently became points of reference; this prompted debates in some countries. In Germany, for example, some questioned the constitutionality of the legal reference in the German joint stock corporations act to the German corporate governance code that was drafted by a government-appointed commission of experts, arguing that the drafting body did not have sufficient democratic legitimacy to draft a text that would become a point of reference in statutory law (see Hommelhoff and Schwab 2003). French law circumvents this problem by not directly referring to a particular text, but allowing a reference to a certain type of corporate governance code, namely any corporate governance code that is drafted by ‘representative business organisations’, which leads to potential competition between different texts. However, in the French case, it is somewhat disturbing that the most prominent code has been drafted by organisations that in effect represent French businesses, precisely those that are obliged to disclose compliance. The drafting of a code by these organizations and the disclosure of an annual evaluation of the application of their own code (see AFEP and MEDEF 2009) could in itself be viewed as a strategic effort to showcase French corporate governance to international investors.

  10. Duhamel and Fasterling (2009) incidentally reveal wrongful or at least incoherent disclosures in the case of ‘comply or explain’ in France.

  11. A case in point may become the Renault CEO’s executive pay for 2009, which was initially reported by the company at €1.2 m and only belatedly took into account an additional payment of about €8 m by Nissan. The affair prompted certain disclosure addressees to question the integrity of executive pay transparency under ‘comply or explain’ mechanisms and call for a stronger reaction to corporate disclosures (see for example Proxinvest 2011).

  12. See, for example, Ruggie (2007) or Catá Backer (2008) for an account of the failure of the draft ‘Norms on the Responsibilities of Transnational Corporations and Other Business Enterprises with Regard to Human Rights’.

  13. Dealing with different ranges of adequate regulatory response is a notion that is inspired by Ayres and Braithwaite’s (1992) regulatory pyramid, of which non-compelling, ‘persuasive’ regulatory measures form the basis and the starting point for consideration of regulatory response. To the extent that soft measures are ineffective, Ayres and Braithwaite propose an ‘escalation‘ of regulatory reactions with coercive options forming the top of the pyramid.

  14. In this sense the law’s function could be viewed as ‘responsive’ (see Nonet and Selznick 2009; Ayres and Braithwaite 1992; Braithewaite 2008 for the concept of ‘responsive law’).

  15. Risk Metrics (2009, p. 186 et seq.) provide an overview of existing legislation in this respect but also note that, to date, shareholders have been passive with regard to compliance disclosures.

  16. For a historic example, see Standard and Poor’s (2004). Standard & Poor’s discontinued its corporate governance rating service in 2005. This rating was overtly designed as a norm proposal, since it sought to ‘serve as a positive discipline and incentive for improvement’ (see Dallas 2004, p. 6).

  17. Janney et al. (2009) provide an analysis of market reactions to adherence to the UNGC, including the effects of failing to complete the annual COP. From the perspective adopted in this article, such research is useful, not to determine the effectiveness of the UNGC as an alternative to substantive regulation, but as a possible indication as to whether disclosure addressees accept the UNGC’s principles as norms for businesses.

  18. One might mention the draft ISO 26000 Guidance on Social Responsibility (International Organization for Standardization 2009), which rejects its use for regulatory or contractual purposes. However, the wording of ISO 26000 is not fully clear on the question of whether it would at least accept to become a reference point for legal disclosure; see International Organization for Standardization (2009, lines 233–241). This rejection is interesting: while the objective is to separate the spheres of law and extra-legal norms (the ISO 26000 standard is designed to provide guidance about responsibilities that go ‘beyond the legal compliance’), it acknowledges the possibility that such a text may in fact evolve into a legally relevant standard, because otherwise there would have been no need to include a clarification in the text that emphasises the legal non-relevance of the Guidance.

References

  • AFEP (Association Française des Entreprises Privées) & MEDEF (Mouvement des Entreprises de France). (2009). Application du code consolidé de gouvernement d’entreprise des sociétés cotées de décembre 2008 par les sociétés de l’indice SBF 120. Exercice 2008, nov. 2009. http://www.medef.com/fileadmin/www.medef.fr/documents/AFEP-MEDEF/Rapport_SBF_120_9_nov_2009__2__17_11_09.pdf. Accessed 30 Apr 2010.

  • Aguilera, R. V., & Cuervo-Cazurra, A. (2003). Codes of good governance worldwide: What is the trigger? Organization Studies, 25(3), 415–443.

    Article  Google Scholar 

  • Aguilera, R. V., & Cuervo-Cazurra, A. (2009). Codes of good governance. Corporate Governance: An International Review, 17(3), 376–387.

    Article  Google Scholar 

  • AMF (Autorité des Marchés Financiers). (2009). Rapport 2009 de l’AMF sur le gouvernement d’entreprise et le contrôle interne of 8 Decembre 2009. http://www.amf-france.org/documents/general/9215_1.pdf. Accessed 30 Apr 2010.

  • Anand, A. (2005). Voluntary vs. mandatory corporate governance: Towards an optimal regulatory framework. Delaware Journal of Corporate Law, 31(1), 229–252.

    Google Scholar 

  • Andres, C., & Theissen, E. (2008). Setting a fox to keep the geese—does the comply-or-explain principle work? Journal of Corporate Finance, 14, 289–301.

    Article  Google Scholar 

  • Arcot, S., Bruno, V., & Faure-Grimaud, A. (2010). Corporate governance in the UK: Is the comply or explain approach working? International Review of Law and Economics, 30(2), 193–201.

    Article  Google Scholar 

  • Ashforth, B. E., & Gibbs, B. W. (1990). The double-edge of organizational legitimation. Organization Science, 1(2), 177–194.

    Article  Google Scholar 

  • Axelrod, R. (1986). An evolutionary approach to norms. The American Political Science Review, 80(4), 1095–1111.

    Article  Google Scholar 

  • Ayres, I., & Braithwaite, J. (1992). Responsive regulation: Transcending the deregulation debate. New York: Oxford University Press.

    Google Scholar 

  • Basu, K., & Palazzo, G. (2008). Corporate social responsibility: A process model of sensemaking. Academy of Management Review, 32(1), 122–136.

    Article  Google Scholar 

  • Belcher, A. (1995). Regulation by the market: The case of the Cadbury code and compliance statement. Journal of Business Law, 1995, 321–342.

    Google Scholar 

  • Bhagat, S., Bolton, B., & Romano, R. (2007). The promise and peril of corporate governance indices. European Corporate Governance Institute, Law Working Paper, n° 89/2007. http://ssrn.com/abstract=1019921. Accessed 22 June 2010.

  • Braithwaite, J. (2008). Regulatory capitalism. How it works, ideas for making it work better. Cheltenham: Edgar Elgar.

    Google Scholar 

  • Calton, J. M. (2006). Social contracting in a pluralist process of moral sense making: A dialogic twist on the ISCT. Journal of Business Ethics, 68, 329–346.

    Article  Google Scholar 

  • Catá Backer, L. (2008). From moral obligation to international law: Disclosure systems, markets and the regulation of multinational corporations. Georgetown Journal of International Law, 39, 591–632.

    Google Scholar 

  • Christmann, P., & Taylor, G. (2006). Firm self-regulation through international certifiable standards: Determinants of symbolic versus substantive implementation. Journal of International Business Studies, 37, 863–878.

    Article  Google Scholar 

  • Committee on the Financial Aspects of Corporate Governance. (1992). The financial aspects of corporate governance. http://www.econsense.de/_CSR_INFO_POOL/_CORP_GOVERNANCE/images/cadbury_report.pdf. Accessed 22 June 2010.

  • Dallas, G. (2004). Governance and risk. New York: McGraw-Hill.

    Google Scholar 

  • de Jong, A., DeJong, D., Mertens, G., & Wesley, C. E. (2005). The role of self-regulation in corporate governance: Evidence and implications from the Netherlands. Journal of Corporate Finance, 11, 473–503.

    Article  Google Scholar 

  • Del Brio, E. B., Maia-Ramires, E., & Perote, J. (2006). Corporate governance mechanisms and their impact on firm value. Corporate Ownership and Control, 4, 25–36.

    Google Scholar 

  • Donaldson, T., & Dunfee, T. W. (1994). Towards a unified conception of business ethics: Integrative social contracts theory. The Academy of Management Review, 19(2), 252–284.

    Google Scholar 

  • Donaldson, T., & Dunfee, T. W. (1999). Ties that bind: A social contracts approach to business ethics. Boston: Harvard Business School Press.

    Google Scholar 

  • Dubbink, W., Graafland, J., & van Liedekerke, L. (2008). CSR, transparency and the role of intermediate organisations. Journal of Business Ethics, 82, 391–406.

    Article  Google Scholar 

  • Duhamel, J. C., & Fasterling, B. (2009). Bilan de l’application du comply or explain par les sociétés françaises du SBF 120. Bulletin Joly Bourse, 2009(6), 524–529.

    Google Scholar 

  • Duhamel, J. C., Fasterling, B., & Refait-Alexandre, C. (2009). La transparence. Outil de conciliation de la finance et du management ? Revue Française de Gestion, 198(199), 59–75.

    Article  Google Scholar 

  • Etzioni, A. (2010). Is transparency the best disinfectant? The Journal of Political Philosophy, 18(4), 389–404.

    Article  Google Scholar 

  • Fasterling, B., & Duhamel, J. C. (2009). Le comply or explain : la transparence conformiste en droit des societies. Revue Internationale de Droit Economique, 23(2), 129–157.

    Article  Google Scholar 

  • Fauvarque-Cosson, B. (2007). La confiance légitime et l’estoppel. Electronic Journal of Comparative Law 11(3). http://www.ejcl.org/113/article113-8.pdf. Accessed 22 June 2010.

  • Fernandez-Rodriguez, E., Gomez-Anson, S., & Cuervo-Garcia, A. (2004). The stock market reaction to the introduction of best practices codes by Spanish firms. Corporate Governance: An International Review, 12(1), 29–46.

    Article  Google Scholar 

  • Financial Reporting Council (FRC). (2009). Review of the combined code: final report, December 2009. http://www.frc.org.uk/corporate/reviewCombined.cfm. Accessed 22 June 2010.

  • Financial Services Authority (FSA). (2009). FSA handbook. http://fsahandbook.info/FSA/html/handbook/. Accessed 22 June 2010.

  • Fung, A., Graham, M., & Fagotto, E. (2006). The effectiveness of regulatory disclosure policies. Journal of Policy Analysis and Management, 25(1), 155–181.

    Article  Google Scholar 

  • Fung, A., Graham, M., & Weil, D. (2007). Full disclosure—the perils and promise of transparency. New York: Cambridge University Press.

    Book  Google Scholar 

  • Goncharov, I., Werner, J.-R., & Zimmermann, J. (2006). Does compliance with the german corporate governance code have an impact on stock valuation? An empirical analysis. Corporate Governance: An International Review, 14(5), 432–445.

    Article  Google Scholar 

  • Goulding, S., Miles, L., & Schall, A. (2005). Judicial enforcement of extra-legal codes in UK and German company law. European Company and Financial Law Review, 2(1), 20–62.

    Article  Google Scholar 

  • Hess, D. (2008). The three pillars of social reporting as new governance regulation: Disclosure, dialogue and development. Business Ethics Quarterly, 18(4), 447–482.

    Google Scholar 

  • Hommelhoff, P., & Schwab, M. (2003). Regelungsquellen und Regelungsebenen der Corporate Governance: Gesetz, Satzung, Codices, unternehmensinterne Grundsätze. In P. Hommelhoff, K. J. Hopt, & A. von Werder (Eds.), Handbuch corporate governance (pp. 51–86). Köln: Otto Schmidt Verlag.

    Google Scholar 

  • International Organization for Standardization. (ISO). (2009). Guidance on social responsibility. Draft International Standard ISO/DIS 26000.

  • Janney, J. J., Dess, G., & Forlani, V. (2009). Glass houses? Market reactions to firms joining the UN global compact. Journal of Business Ethics, 90, 407–423.

    Article  Google Scholar 

  • MacNeil, I., & Li, X. (2006). Comply or explain: Market discipline and non-compliance with the combined code. Corporate Governance: An International Review, 14(5), 486–496.

    Article  Google Scholar 

  • Madsen, P. (2009). Dynamic transparency, prudential justice, and corporate transformation: Becoming socially responsible in the internet age. Journal of Business Ethics, 90, 639–648.

    Article  Google Scholar 

  • Meyer, J. W., & Rowan, B. (1977). Institutionalized organizations: Formal structure as myth and ceremony. The American Journal of Sociology, 83(2), 340–363.

    Article  Google Scholar 

  • Nonet, P., & Selznick, P. (2009). Law and society in transition. Toward responsive law (2nd ed.). New Brunswick: Transaction Publishers.

    Google Scholar 

  • Nowak, E., Rott, R., & Mahr, T. G. (2005). Wer den Kodex nicht einhält, den bestraft der Kapitalmarkt? Zeitschrift für das gesamte Gesellschaftsrecht, 34(2), 252–279.

    Google Scholar 

  • OECD, Organization for Co-operation and Development. (2008). OECD guidelines for multinational enterprises. http://www.oecd.org/dataoecd/56/36/1922428.pdf. Accessed 22 June 2010.

  • Palazzo, G., & Scherer, A. G. (2006). Corporate legitimacy as deliberation: A communicative framework. Journal of Business Ethics, 66, 71–88.

    Article  Google Scholar 

  • Parker, C. (2002). The open corporation. Cambridge: Cambridge University Press.

    Google Scholar 

  • Parker, C. (2008). The pluralization of regulation. Theoretical Inquiries in Law, 9(2), 349–361.

    Article  Google Scholar 

  • Pettit, P. (1990). Virtus normativa: Rational choice perspectives. Ethics, 100(4), 725–755.

    Article  Google Scholar 

  • Proxinvest. (2011). Proxy active investors—Renault: Say on pay, http://www.proxinvest.com/media/Resolution_RENAULT_2011.pdf. Accessed 1 Feb 2011.

  • Ratner, S. R. (2001). Corporations and human rights: A theory of legal responsibility. The Yale Law Journal, 111(3), 443–545.

    Article  Google Scholar 

  • Ripken, S. K. (2006). The dangers and drawbacks of the disclosure antidote: Toward a more substantive approach to securities regulation. Baylor Law Review, 58, 139–204.

    Google Scholar 

  • Risk Metrics. (2009). Study on monitoring and enforcement practices in corporate governance in the member states. Study commissioned by the European Commission. Contract No. ETD/2008/IM/F2/126, September 2009. http://ec.europa.eu/internal_market/company/ecgforum/studies_en.htm. Accessed 22 June 2010.

  • Rodriguez, T. S. (2000). Extending the fraud-on-the-market theory: The second circuit’s connection test for SEC Rule 10b-5. The Journal of Corporation Law, 25(2), 423–443.

    Google Scholar 

  • Rodrigues, U., & Stegemoller, M.A. (2010). Placebo ethics. Virginia Law Review (Forthcoming), UGA Legal Studies Research Paper No. 09-003. Available at SSRN: http://ssrn.com/abstract=1364220. Accessed 22 Dec 2010.

  • Ruggie, J. G. (2007). Business and human rights: The evolving international agenda. The American Journal of International Law, 101(4), 819–840.

    Google Scholar 

  • Scherer, A. G., Palazzo, G., & Baumann, D. (2006). Global rules and private actors: Toward a new role of the transnational corporation in global governance. Business Ethics Quarterly, 16(4), 505–532.

    Google Scholar 

  • Standard & Poor’s. (2004). Corporate governance scores and evaluations, criteria, methodology and definitions. New York: McGraw-Hill.

    Google Scholar 

  • Stevens, J. M., Steensma, H. K., Harrison, D. A., & Cochran, P. L. (2005). Symbolic or substantive document? The influence of ethics codes on financial executives’ decisions. Strategic Management Journal, 26, 181–195.

    Article  Google Scholar 

  • Suchman, M. C. (1995). Managing legitimacy: Strategic and institutional approaches. Academy of Management Review, 20(3), 571–610.

    Google Scholar 

  • Tapscott, D., & Ticoll, D. (2003). The naked corporation. New York: Free Press.

    Google Scholar 

  • United Nations Global Compact Office. (2009). Policy for communication in progress. Updated 3 April 2009. http://www.unglobalcompact.org/docs/communication_on_progress/COP_Policy.pdf. Accessed 22 June 2010.

  • United Nations Global Compact Office. (2010). Policy on the use of the global compact name and logos. Updated 15 January 2010. http://www.unglobalcompact.org/docs/about_the_gc/logo_policy/Logo_Policy_EN.pdf. Accessed 22 June 2010.

  • Vaccaro, A., & Madsen, P. (2009). Corporate dynamic transparency: the new ICT-driven ethics? Ethics and Information Technology, 11(2), 113–122.

    Article  Google Scholar 

  • von Werder, A., Talaulicar, T., & Kolat, G. L. (2006). The German corporate governance code: general acceptance and neuralgic norms—a second look. International Journal of Public Policy, 1(4), 435–450.

    Article  Google Scholar 

  • Weil, Gotshal & Manges. (2002). Comparative study of corporate governance codes relevant to the European Union and its member states. Study on behalf of the European Commission, Internal Market Directorate General, January 2002. http://ec.europa.eu/internal_market/company/docs/corpgov/corp-gov-codes-rpt-part1_en.pdf. Accessed 22 June 2010.

  • Weir, C., Laing, D., & McKnight, P. (2003). An empirical analysis of the impact of corporate governance mechanisms on the performance of UK firms. http://ssrn.com/abstract=286440. Accessed 30 Apr 2010.

  • Westphal, J. D., & Zajac, E. J. (1994). Substance and symbolism in CEOs’ long-term incentive plans. Administrative Science Quarterly, 39(3), 367–390.

    Article  Google Scholar 

  • Westphal, J. D., & Zajac, E. J. (2001). Decoupling policy from practice: The case of stock repurchase programs. Administrative Science Quarterly, 46(2), 202–222.

    Article  Google Scholar 

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Acknowledgements

This article is a part of a joint research project dealing with the theme ‘Transparency and Information Disclosure in Corporate Governance’. The multidisciplinary project is funded by the French National Research Agency (ANR Contract 07-ENTR-012). This project brings together research teams from LegalEDHEC (EDHEC Business School); CRDP-LERADP (University of Lille 2) and EQUIPPE (University of Lille 1). I thank my colleagues Catherine Refait-Alexandre and Jean-Christophe Duhamel with whom I have been working closely on the aforementioned project. This article also benefited from the conversations that I had with the participants of the EBEN Annual Conference 2010 in Trento. Finally, I am grateful to the two anonymous reviewers for the care with which they reviewed the original manuscript and for their suggestions that helped improving the article.

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Fasterling, B. Development of Norms Through Compliance Disclosure. J Bus Ethics 106, 73–87 (2012). https://doi.org/10.1007/s10551-011-1055-y

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