CSR Agenda: National and Cultural Influences on Corporate Social Responsibility

Sit in on a corporate social responsibility meeting in Mumbai, and you will hear terms like “Schedule VII,” “net profit threshold,” and “CSR committee.” Sit in on a similar meeting in Johannesburg, and the vocabulary shifts entirely – “B-BBEE scorecards,” “transformation,” “corporate social investment.” Same three letters, completely different conversation. That is the central truth about corporate social responsibility: it is never written on a blank page. Every country’s CSR agenda carries the fingerprints of its own history, politics, and social wounds. Understanding this is essential for anyone studying business, because it explains why a strategy that works brilliantly for a company in one country can fall flat – or even seem tone-deaf – in another.

Why CSR is never one-size-fits-all 🔗

Corporate social responsibility did not emerge from a single global rulebook. It grew, in different countries, out of different institutional soil – different legal systems, different relationships between business and government, and different ideas about what companies owe to society. Management scholars Dirk Matten and Jeremy Moon captured this well in their influential distinction between explicit CSR and implicit CSR. In countries like the United States, CSR tends to be explicit: companies voluntarily design their own branded programmes and publicise them. In much of Continental Europe, by contrast, social responsibility is more implicit – baked into labour law, welfare systems, and industry norms, so companies do not need to “announce” it as a separate initiative. As the original framework explains, these differences trace back to each nation’s historically grown institutions and business systems.

This idea matters far beyond the US-Europe comparison it was originally built for. It gives us a lens to understand why India’s CSR agenda and South Africa’s CSR agenda look so different, despite both being emerging economies with colonial pasts and significant income inequality. Each country’s CSR story is really a story about what its society needed to fix, and who it trusted to fix it.

India’s CSR agenda: from temple donations to Section 135 🔗

A tradition of trusteeship, not obligation 🔗

Long before “CSR” was a management term, wealthy Indian merchants and industrialists were funding temples, wells, and medical facilities as an extension of religious and family duty. In the nineteenth and early twentieth centuries, industrial houses such as Tata, Birla, Godrej, and Bajaj built schools, hospitals, and townships around their factories, blending economic ambition with a sense of paternalistic responsibility toward workers and communities. This era was deeply shaped by Mahatma Gandhi’s theory of trusteeship, which held that industrialists should see themselves as trustees of wealth on behalf of society rather than its sole owners. This philosophy became, in many ways, the moral foundation on which India’s later CSR framework was built.

From voluntary guidelines to statutory law 🔗

For most of independent India’s history, CSR remained a voluntary, philanthropic activity – generous in places, patchy overall, and entirely dependent on a company’s goodwill. That changed in 2009, when the Ministry of Corporate Affairs introduced the National Voluntary Guidelines on Social, Environmental, and Economic Responsibilities of Business, an early attempt to nudge companies toward more structured social spending. These guidelines eventually evolved into hard law: the Companies Act, 2013 made CSR spending mandatory for qualifying companies from April 2014 onward, through Section 135. Any company crossing a specified net worth, turnover, or profit threshold must now spend at least two percent of its average net profits on activities listed in Schedule VII, ranging from education and healthcare to rural development and disaster relief.

This shift – from voluntary trusteeship to legally enforced spending – is what makes India’s CSR agenda genuinely unusual on the world stage. Few other countries have converted social responsibility into a direct legal obligation with penalties attached for non-compliance. A parliamentary committee’s push for accountability, combined with growing public expectation that large companies “give back” in visible ways, is part of what drove this legislative shift, turning what was once discretionary charity into a structured, board-level responsibility.

CSR as market development and global positioning 🔗

India’s CSR agenda has also grown a second, less discussed dimension: it is increasingly tied to market development and global competitiveness. As multinational companies set up operations in India, and Indian companies expand overseas, CSR spending has become part of how businesses build local trust, secure a “license to operate” in underserved regions, and signal responsible governance to global investors. Skill development programmes, for instance, do double duty – they satisfy a company’s Schedule VII obligations while also building the very workforce that company will eventually hire from. In this way, India’s CSR agenda has moved from pure philanthropy to something closer to strategic community investment, without losing its older, more spiritual roots in trusteeship.

South Africa’s CSR agenda: from charity to structural transformation 🔗

Corporate philanthropy under apartheid 🔗

South Africa’s CSR story begins in a very different place. For much of the twentieth century, corporate giving in South Africa took the form of charitable donations and welfare funds, often organised around mining conglomerates and their founding families. This philanthropy was real, but it operated inside a system – apartheid – that had systematically excluded the country’s black majority from land ownership, corporate investment, and economic opportunity for generations. No amount of charitable giving could address a problem of that scale, because the exclusion was structural, not incidental.

B-BBEE and the post-1994 shift 🔗

Everything changed with the end of apartheid in 1994. South Africa’s new democratic government needed corporate responsibility to do far more than fund hospitals and schools – it needed business to actively help dismantle economic exclusion. This is where Broad-Based Black Economic Empowerment (B-BBEE) enters the picture. Formalised through legislation in the early 2000s, B-BBEE pushes companies to bring black South Africans into ownership, management, and skills pipelines, sometimes through the sale of equity stakes to empowerment groups. As research on BEE transactions notes, this policy has become one of the most significant drivers of transformation in South Africa’s economic and corporate landscape since apartheid ended.

B-BBEE effectively turned CSR in South Africa into something with teeth: companies are scored on ownership diversity, management representation, skills development, and enterprise development, and that scorecard affects everything from government contracts to investor confidence. This is a markedly more structural approach than India’s Schedule VII model, which focuses on where money is spent rather than who holds equity and power inside the company itself.

Corporate social investment: a uniquely South African term 🔗

Alongside B-BBEE, South African business developed its own distinct vocabulary: Corporate Social Investment (CSI). Unlike the broader, internationally used term “CSR,” CSI specifically refers to a company’s voluntary social spending – historically concentrated on education, healthcare (including the country’s HIV/AIDS response), and community welfare. Over time, this spending has moved beyond one-off charitable donations toward more sustainable, partnership-based development work, often coordinated with government and civil society. As one academic account of the shift describes, CSR discourse in South Africa progressed from an early emphasis on philanthropic corporate social investment toward a more integrated approach linked to sustainable development and collaborative governance. In short, South African CSR carries the memory of what corporate silence and complicity allowed under apartheid, and much of its current agenda is a direct response to that history.

India and South Africa side by side 🔗

Placing the two agendas next to each other makes the influence of national history unmistakable.

Notice the difference in what each system is trying to fix. India’s CSR law responds to underinvestment in public goods like education, health, and rural infrastructure, in a large developing economy where government resources are stretched thin. South Africa’s CSR agenda responds to something narrower but deeper: a specific historical injustice that concentrated wealth and opportunity along racial lines, and that only structural ownership changes can meaningfully address. Both are legitimate, serious answers to real problems – they are just answers to different questions.

What this means for businesses and business students 🔗

For any company operating across borders, this comparison is not just an academic exercise. A CSR strategy that works well in India – heavy investment in schools, health camps, and skill centres – will not automatically satisfy expectations in South Africa, where stakeholders will ask harder questions about ownership, board representation, and who actually benefits from a company’s profits. Similarly, a South African-style transformation scorecard would need significant adaptation to fit India’s social and legal context, where caste, regional disparity, and rural-urban divides shape need in different ways than race-based exclusion does.

For students of business organisation and management, the lesson is broader than either country’s specific rules. CSR is not a checklist that can be copied and pasted across markets. It is a reflection of what a society has decided business owes it, based on that society’s own history. Companies that treat CSR as a purely global, standardised function – the same brochure everywhere – tend to miss this local depth, and often end up with programmes that look good on paper but feel hollow to the communities they are meant to serve.

What do you think? If a company operates in both India and South Africa, should its CSR agenda stay rooted in each country’s distinct history, or is there a case for one unified global CSR philosophy? And as India’s economy matures, do you think its CSR agenda will shift further toward structural issues, the way South Africa’s did after 1994?

References

1. https://carleton.ca/ces/wp-content/uploads/MattenMoon-in-AMR-2008.pdf
2. https://www.csr.gov.in/content/csr/global/master/home/aboutcsr/history.html
3. https://journals.publishing.umich.edu/sdi/article/id/3709/print/
4. https://www.sciencedirect.com/science/article/abs/pii/S0024630111000057
5. https://link.springer.com/chapter/10.1007/978-3-540-68815-0_20