Building an Ethical Agency Culture: Kim Sample

Joining me on this week’s episode of Ethical Voices is Kim Sample. Kim is President of the PR Council and she helps the PR Council’s 100+ member agencies thrive and work, to elevate the PR profession overall and to help build an ethical agency culture. Prior to joining the PR Council in August, 2018, Kim was the Founder and CEO of Emanate, a $35 million, 100+ person international marketing communications agency.

Over the course of our ethics discussion, Kim touches on a number of key issues, including:

Why don’t you start off by telling us a little bit more about yourself and your career?

I am definitely what you would call an agency animal. I worked in an art gallery for a couple of years when I graduated with my art history degree, and I found it to be just too slow for me, so I got my first job as a junior secretary in an advertising and PR firm in Washington D.C. I have been in agencies ever since. I have worked in boutique, specialty agencies, I have worked for very large agencies, I’ve created an agency from zero, and I really love the business. I have never had a boring day since I started agency business.

Thinking back over your career and all the experiences you’ve had, what is the most difficult ethical challenge you ever confronted at work?

I think there are almost daily ethical questions and I think most of the ethical challenges that we face are small calls that we need to make. I’ve had some assignments that were questionable in taste. I don’t know if they were entirely unethical. Early in my career, I worked for a lot of different beer companies and we did some things that weren’t great, like one of the things I worked on was a surf lifesaving competition that was sponsored by Molson Beer. That didn’t make much sense.

But then I think there are the outright ethical issues. I had a client a long time ago who had gotten a test opportunity in a single Home Depot store and they really had to demonstrate great sales results to get into more stores. So, the client came to our team with the question, “Well, what if you the agency, went and just bought our product? Made that store sell out.”

Well, no, we can’t do that.

So, when the client asked you to do something unethical, What’s the decision-making process you go through? Especially when you’re pushing back on the management team.

I was a bit more junior in my career so I had really great support from the agency leadership when I said, “Hey, we were asked to do this. This doesn’t feel right. This isn’t something I want our team doing.” They supported me, I took it to the client and said, “Well, we can’t do this, but here’s what we can do. Here’s how we can try to support this incredible opportunity you have in a more ethical way.”

Upon hearing it, they understood immediately that what they had asked was not appropriate. Now, do I know if they got some other agency to go purchase the product? I’m not 100% sure. I hope not.

Thinking beyond your own career, and particularly as your role as President of PR Council, what are you seeing as some of the key PR ethics challenges for today and tomorrow?

I’m focused on a few things. Of course, at the PR Council, to become a member of the council you have to sign our code of ethics and you re-sign it every year. It’s not something it’s one and done. Every year we want to put that code of ethics in front of you. We also take a step back every year and think about the ways we need to modify it and we’re getting ready to do that for 2020. The business is changing so rapidly that there are constantly new considerations.

But to have great ethical practices, it’s a lot more than just reading over a code of conduct and signing it. It requires ongoing conversations with staff from top to bottom. So that people understand what’s expected of them, their antenna is immediately up if they’re put in a situation that is not right, and they feel very comfortable surfacing ethical concerns, know they’re going to get full attention and a really good conversation and support.

We’re hearing right now from agencies across the country that they’re seeing a lot of sensitive new business opportunities and are really having to think about how to respond to that. In fact, we’ve seen in the news, not new business opportunities, but really some sensitive client issues and I think sometimes that happens where the employee base may not like what the business itself does, or maybe the business has a bit of a misstep and that’s upsetting to employees.

We’ve got to make sure that our agencies have really strong, clear value statements that serves as a guide when making these decisions. I think businesses today have to be really in touch with their employees and what their employees consider great business to work on and what they don’t. There’s a little bit of reality that comes into that as well.

You’re working for for-profit businesses so those conversations have to take place as well. But I think having a really great values system, I think having places where employees can surface their discomfort and have conversations about their discomfort is really important. There’s no putting that employee activism genie back in the bottle, but let’s make sure there are internal opportunities for ethics quandaries to be discussed and resolved so it doesn’t all happen out on social media or on a public stage.

When you were talking about really making sure organizations have clear values and clear ethics training what are your recommendations? What have you done to really help ensure that people understand the ethical values of your organization?

We’re very lucky at the council that FleishmanHillard, when Dave Sinai was our chair of the board, he offered to make Fleishman’s ethical training available to all of our members. We continue to do that to this day. In fact, in the fall we will do more training around that. I think having a written code of conduct, an ethics statement, that all employees read and sign is a step similar to our step of getting agencies to sign that.

But then it’s having those discussions and whether you have some sort of online training that you’re doing, or there’s an actual class that people are going to, I think that’s super important, but to me, it’s being able to have those discussions. Because as you know, there’s so much that’s in the gray area. That’s where you need to have conversations and help people be able to spot what’s the right thing to do in situations they find themselves in.

I call it training your ethical mind, is the way that I look at it, training needs to be ongoing, so you can get more comfortable making the decisions when you’re under pressure, and do not have a lot of time. Doing it just once a year isn’t usually enough.

And that’s one thing that really worries me about agencies today. The pace is just out of control. There’s so little time and I think somehow, we’ve got to find the time to slow down and make sure we’re talking about ethics and how important they are. A new Gallup poll just came out that put public relations and advertising pretty far down the list of respected businesses.

For our industry to continue to grow, to be able to continue to attract the best and the brightest, we’ve got to improve our reputation and a key piece of that is the ethical decision making that happens day in, day out in our business. We’ve got this legacy to overcome. I think the industry is so much better than we get credit for, but we’ve got to do the work to overcome that, because that reputation just hangs over our heads.

You know what I have found through my career? And I bet it’s the same for you and many, many others out there, is we actually help companies do the right thing. It’s not that they don’t want to do the right thing, but I think sometimes when you’re wearing your internal lens, you can’t see it. That’s what’s been exciting about this business, is you get to help companies see the right thing to do, and then to take the steps to have the appropriate overreaction, and I think that’s the classic advice in issues and price management, and I think it’s right for ethical considerations as well. Like, go one step beyond the base ethical boundary. Always do the right thing.

You’ve mentioned there’s an increasing number of sensitive new business opportunities and putting you on the spot here, what is your point of view? Does every company have a right to PR counsel?

It’s so hard. I think every company has a right to PR counsel if they’re going to listen and actually take action. I’m not interested in those clients who don’t want to do the right thing and are not going to take our council, and are never going to change their ways. Unfortunately I think there are a few businesses like that, not many, but I think it’s really challenging right now because our employees don’t want to work for lots of different business. I’ll give a very specific example.

At two different times in my career, I did really gratifying, important work for Ringling Brothers, and one of them was helping them with their animal care program, hiring a senior director of animal care. It was really gratifying because they were committed to doing all of the right things. Another time, I was working in Japan and helped launch the circus to the Japanese market. I loved working with them. Another opportunity rolled around when I was at Emanate and my employee base was not at all excited about the opportunity.

They really could not support it because of the animal issues and we had to decline. I think you’ve got to understand what your employees care about, what they can feel good about working on, and make really good choices. Sometimes you don’t have that luxury. We are for-profit businesses but I think trying to be very careful about finding clients who want to do the right thing, want to be better, want to listen to council, I think that’s the key.

I think you hit on a key point about respecting your employees’ wishes. I mean, there were times when I was doing PR for online dating companies and some of the things they asked us to do were definitely interesting and you need to make clear to the staff that if you’re not comfortable working on this and you’re not comfortable doing this, that’s fine. We won’t put you on it, we’ll have somebody else do the work and there’ll be no negative repercussions that you’ll be facing for that, because we really need to respect your own ethical guidelines as well.

Yeah, but what worries me is that’s not enough in this age of employee activism. So, I think there’s education that we need to do to help our employees understand that we are for-profit businesses and we try to make really great decisions, but they’re not always going to be 100% in agreement with our decisions, but here are our stated values that we are operating in compliance with. Make sure that the time is taken to talk people through things and answer questions in really transparent, forthcoming ways.

You mentioned that the PR Council occasionally revises its code of ethics, what were some of the more recent provisions or changes you’re making?

I think that we’ve really got to dig in on our ethics around influencer marketing and make sure that we have got all of the right disclosures clearly stated there. I think privacy is now a very legal issue, but I think that needs to be covered in ethics as well.

And then I do think on these sensitive clients, having a commitment to having those conversations and making sure that the clients we represent are aligned with our firm values is important to be in the ethics as well.

When it comes to influencers, is there any guidance or recommendations you have on how to ethically disclose your activities and involvement with them?

I’m really not an expert in that, but we are bringing in lots of experts ranging from legal counsel to firms that really specialize in that, and we’ll pull all of the most up-to-date recommendations in to make sure we’re giving our members really great guidance on that.

If members want to get guidance or if people want to know more about PR Council and its code of ethics, where they should go for information?

You can find a lot of it on our website, We have a brand new site that we think is really well organized and people can find their way around. It’s in the About Us section, and we’re always happy to have conversations. In fact, a lot of what we do is create opportunities for agencies to learn from each other. We do a lot of member round tables in markets across the country. We’re constantly creating events that have networking and conversation as a key element. We’re trying to build the best possible agencies and agencies that will be successful in the future have to have really great ethical grounding and ethical practices. It is a very important element of what we do.

Thinking back, what is the best piece of ethics advice you were ever given?

I think it definitely was to appropriately overreact. Do the right thing, don’t just barely do the right thing. Like, try to take it a step further. Go a little bit above and beyond to make sure you’re doing the right thing and presenting yourself, your firm, and your clients in the most ethical way possible.

Is there anything else you wanted to add that I didn’t ask you about?

I just think professionals in our industry, whether you are two minutes out of college and in an agency the first time, to incredibly seasoned professionals who have spent careers in agencies, taking the time to think about the things you’re doing, to have conversations, to ask questions, to know if your gut says all isn’t well, trust your gut. I think one of the best things PR people can do is make sure they’re asking questions. Don’t just leave things at the surface. Maybe it’s something a client’s telling you and you’re like, “Ugh, I’m not sure.” Ask more. You can’t counsel your clients particularly on ethical issues, if you aren’t asking a lot of questions and really getting all of the information.

I think sometimes what happens with agencies is you stop leading the client sometimes and you’re taking orders. Like, we can’t take orders. We are not serving clients well if we’re taking orders and we’re not questioning and offering real great counsel.

Listen to the full interview, here:


Mark McClennan, APR, Fellow PRSA
Follow Me
Mark W. McClennan, APR, Fellow PRSA, is the general manager of C+C's Boston office. C+C is a communications agency all about the good and purpose-driven brands. He has more than 20 years of tech and fintech agency experience, served as the 2016 National Chair of PRSA, drove the creation of the PRSA Ethics App and is the host of


Leave a Reply

Your email address will not be published. Required fields are marked *