**1. Introduction**

Corporate Social Responsibility (CSR) ensures commitment of corporates to humanity. It is not in a charitable sense but a responsibility owed for the resource use. CSR as a coinage of legal vogue is relatively of recent provenance. As an operable concept, one cannot set finger on a definite date. It is understood to have a rough conceptualization as a business concept in 1914 when Fredrick Goff, a reputed banker established Cleveland Foundation with the objective of accepting donations from multiple sources and utilize it for philanthropic purposes [1, 2]. According to [3], the concept of CSR takes road in Rome where the ancient laws prescribed for asylums, homes for poor and old etc. This concept of social responsibility of corporations he posits was adopted in the English Law in the Middle Ages. The Crown substantialized corporations as vehicles of social development. This role of social development via corporations was then exported to the Crown's colonies. Even before Romans, and the English systems, in India, the ancient texts, that is, the Vedas prescribed the concept of CSR although not in several and clear words. In [4], the Vedic texts are interpreted to point towards core CSR principles. Vedas mention that the economic structure

should be developed on the basis of 'Sarva loka hitam', which means 'wellbeing of all the stakeholders'. The ecosystem of businesses forms a big part of large economic structure and, if viewed from the Vedic perspective, it underlines the implicit social commitments that the businesses must espouse. With the pinnacle advent of 'age of industrialization' in the mid and late nineteenth century, new challenges for small business and labour market cropped up. To sooth the challenges, businesses introduced and began creating workplace value for the labourers in form of better working conditions [5].

The introduction of the term CSR surfaced in 1950s to chalk out the boundaries of the corporations. It was during this decade of 1950–1960 when academic scholarship gained traction for attempting to start CSR research on a social level of analyses [6]. The research provided necessary impetus for a structured system of CSR. CSR Policies of different countries are modelled on different considerations, viz., philanthropic, ethical, legal, and economic or an amalgam of these. The aim of the chapter is not to lay down a detailed map on theoretical considerations of CSR policy, rather the aim is to study the nature of CSR policies in select countries. It is imperative to know the content of the CSR policy not only from the standpoint of practical pondering and deliberations. It is equally be-telling of the government's commitment to hold the corporations socially accountable. It has been briefly informed above that CSR like activities were majorly mandated through laws or government's/Crown's diktats. Placed alternatively, some external authority was required to make the businesses socially responsible. The first question that passes the mind appertains to how the business is made socially responsible? The answer though may appear to be simple by way of regulation but saying so would be far from the truth, both in theory and practice. The current research also aims to unravel the complexities that underlie in the drafting of CSR Policy. A CSR policy may be explicit, or prevail purely in practice. Again, the nature, and scope such policy varies according to several domestic considerations. For the purpose of examining, it in fair manner, comparative analysis is used. Further, the functional utility of the research lies in CSR policy reform.

The previous studies in CSR Policy reform exhibit a gap in comparative studies in CSR legal policy. In fact, it is still in its nascent stages and is labelled as an "emergent field" [7]. As correctly pointed out in [8], empirical studies produce non-comparable results owing to different operational definition of CSR. The studies in the comparative CSR field have a lot to offer from a legal policy reform perspective but have been not opted for frequently. In this light it becomes important to have a glance through the existing literature in the mentioned context. It is not intended to be a comprehensive survey of the literature. The literature points towards the growing trend of inter-country CSR study for the purposes of cross-country learnings and policy reform. No findings of the previous studies could be compared to the present study in lock, stock and barrel since the three countries selected form a unique set of analysis for comparison. Factoring this caution in mind, a brief literature survey would be helpful in establishing the gap that the required study intends to fill, in particular, and the utility of cross-country comparisons in general.

In [8], different types of comparative studies for CSR outlined which replace the unit of analysis for comparison. It posits the comparisons could be legal or institutional. The former centres on the governmental policy of CSR, while the latter on various stakeholders involved in the CSR across countries like investors, employees, top management etc. The illustrative examples are majorly drawn from the West which serves as a shortcoming [8, 9]. Later academic scholarship began becoming inclusive with comparing the west with the global south countries, for instance,

#### *CSR Policies in Different Countries: A Comparative Analysis DOI: http://dx.doi.org/10.5772/intechopen.106612*

with South Africa [10]. The findings of the study confirm that CSR activities depend on the socio-political settings of a country at least when UK and South Africa were compared [10]. In 2016, a breakthrough scholarship emerged that focused on multiple countries CSR policies [11]. It however missed on India and Norway as countries of study. In order to plug the scholarly gap, the current research studies US, Norway and India's CSR policies.

In order to facilitate a systematic enquiry, the chapter is divided in four parts. The first part is the introduction itself; the second part delves into government's role in CSR promotion generally. The next part forms the main thrust of the chapter where CSR policy of different countries are analyzed. The last part comprises of conclusion and suggestions for reforms. Comparative CSR could be in terms of continents, region like European Union or SAARC, institutions, or stakeholders. Inter-country comparisons still less picked unit of study.

Before moving on to next part, a few clarifications merit mention. First, it is impossible to be exhaustive on CSR policy of different countries but being illustrative would suffice the understanding. Second, commitment of government is assessed in terms of nature of CSR policy. Third and a related point, there may be other parameters to assess the role of government towards CSR but policy pursual on any given matter is reflective of the commitment in the strongest, thus policy is considered to be reflective of the degree of government's commitment to CSR. Fourth, all comparisons would be arbitrary depending on the perspective and points of comparison. The countries selected for CSR policy comparison are on the basis of CSR rankings [12]. These countries as the readers will see in the following parts also exhibit eclectic approaches to CSR policy. Authors have used qualitative-doctrinal approach to research.
