The International Code of Conduct provides a further case study in understanding how PMC regulation and legitimacy may be transforming. Once again, Fabienne's framework of legitimacy provides an expedient definition and theoretical framework. Fabienne addresses legitimacy in the context of what he terms “[…] Political Cosmopolitanism”. Political Cosmopolitanism can be regarded as a form of international legitimacy. At a minimum, it is “[…] the view that national communities are not the exclusive source of political legitimacy in the global realm.” Indeed, it is possible to consider Political Cosmopolitanism as an antithesis to Wyatt-Walter's Global Hegemony. In other words, if globalization has led to or is resulting in the commodification of sensitive goods and services such as security, then there is a transformation of political actors on the international plane. States do not remain the dominant actors of such commodification. In turn, Fabienne argues, “[…] the main problem of legitimacy at the international level” becomes the rise of actors that may complicate, willingly or unwillingly, “[…] democratic accountability [to states]”. This complication thus births the need for global governance institutions. Such institutions, including Civil Society are not intended to supplant the authority of states but must act as “[…] [regulatory] coordination devices […] to solve problems that arise at the global level.”

Simultaneously, Fabienne discusses an inherent problem with a global governance approach. Although there may be “[…] widespread agreement that global institutions […] are necessary, there will be widespread disagreement about which particular institutions are necessary and what rules they should issue”. It is for this reason “[…] that new modes of governance must be created, with their own structures of accountability.” This latter observation creates an expedient role for the ICoC. The International Code of Conduct and the ICoC Association (ICoCA) stand as such a form of regulation, if not pure global governance. The ICoC, through the ICoCA, features its own accountability mechanisms, overseen by the pillars of Government, Industry and Civil Society. Utilizing Fabienne's Political Cosmopolitanism, it can thus be assumed that the ICoC unites these three pillars in a form of global self-regulation to govern the international PMC sector. It should thus be expected that state and PMC members acknowledge the legitimacy of the ICoC in their respective ‘selfrhetoric’ or public rhetoric. It should also be expected that any corporate codes of conduct from signatory firms reflect ICoC principles.