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Amodu, Nojeem (2020) 'Stakeholder Protection and CSR from Comparative Company Law Perspective: Nigeria and South Africa.' Journal of African Law, 64 (3). pp. 425-449.

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There have been notable legislative advancements and improvements in corporate governance codes towards stakeholder rights protection. But, how much protection have they really afforded stakeholders against social irresponsible corporate behaviours? The article undertakes a comparative analysis of the legal framework underlying the stakeholder-inclusive approach in South Africa and the environment, social and governance (ESG) or sustainability corporate reporting in Nigeria. It identifies faulty philosophical background together with policy misalignment of corporate governance codes and primary corporate law as critical factors undermining efforts to embed responsible corporate behaviour towards safeguarding qualified and legitimate stakeholder interests. It recommends specific amendment provisions which address the ideological defect and aligns corporate governance codes with primary corporate legislations in the countries.

Item Type: Journal Article
Keywords: Comparative company law, CSR, Nigeria, South Africa, stakeholder protection
SOAS Departments & Centres: Departments and Subunits > School of Law
ISSN: 00218553
Copyright Statement: © SOAS, University of London 2020. This is the accepted manuscript of an article due to be published by Cambridge University Press in Journal of African Law. Available online:
DOI (Digital Object Identifier):
Date Deposited: 10 Dec 2019 11:38
Funders: Other

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