There have been notable legislative advancements, as well as improvements in corporate governance codes, aimed at protecting stakeholder rights. However, how much protection have they really afforded stakeholders against socially irresponsible corporate behaviour? This article undertakes a comparative analysis of the legal framework underlying South Africa's stakeholder-inclusive approach and Nigeria's environmental, social and governance or sustainability corporate reporting. It identifies a misplaced philosophical background as well as policy misalignment of corporate governance codes and primary corporate law as critical factors that undermine efforts to embed responsible corporate behaviour in order to safeguard the interests of qualified and legitimate stakeholders. It recommends specific amendments to address the ideological defect and align corporate governance codes with primary corporate legislation in these two countries.

旨在保护利益相关者权利的立法取得了显着进步，公司治理法规也得到了改善。但是，他们真正为利益相关者提供了多少保护，使其免受社会上不负责任的公司行为？本文对南非的利益相关者包容性方法和尼日利亚的环境，社会与治理或可持续性公司报告所依据的法律框架进行了比较分析。它确定了错误的哲学背景以及公司治理守则和主要公司法律的政策失调，这些因素是破坏为确保合格和合法股东的利益而埋下负责任的公司行为的努力的关键因素。