A comparative analysis of corporate governance and CSR: lessons from India, UK and USA

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India mandates CSR investment through the Companies Act, focusing on social initiatives for certain businesses.
The UK has a comply or explain governance model that encourages voluntary CSR projects under ESG standards.
The USA balances corporate governance with shareholder value preservation through legislation like Sarbanes-Oxley.
The study highlights significant differences in regulatory enforcement and governance theories among the three countries.

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Analysis compares corporate governance and CSR systems in India, UK, and USA, highlighting regulatory differences and implications.

Gupta et al. (2025) studied this question.

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