4.2.3. Disclosure Approaches

The following pattern or trend is disclosure approaches as presented in Figure 7. The papers grouped under this theme examine disclosure approaches by countries in managing non-financial information by suggesting recommendations for improving the law or applying new theories in addressing transparency issues. For example, one study discussed the disclosure approaches in the United States and European jurisdictions, specifically the United Kingdom and France, and the transparency model for human-rights protection for companies' activities [70]. Another study examined the disclosure provisions in the United Kingdom Code of Corporate Governance as a case study [65]. At the same time, Berger-Walliser and Scott [71] reviewed the legalization of corporate social responsibility in the United States, the European Union, and China.

**Figure 7.** Papers under the theme of disclosure approaches [29,65,70–77].

It is intriguing to see that those studies relating to the theme of disclosure approaches started in 2018, whilst there are none consecutively in the years 2014, 2015, 2016 and 2017. This theme started to gain popularity from 2018 to 2020, when six papers in 2020 examined issues concerning this theme. In the year 2019, Ho and Park [29] proposed reforming the disclosure framework by suggesting the amalgamation of public regulations and private ordering, and in that attempt the researchers conducted their investigation in the United States, South Africa, Brazil, the European Union, the United Kingdom, Hong Kong, and China. This study is the only publication related to this theme of disclosure approaches in 2019.

The number of papers published in the year 2020 surged to six, and from observation, the concerns of each study were different. Hence, it is essential to present the purpose of the papers published in 2020, to observe the areas discussed and investigated. Kinderman [72] investigated the link between corporate social-responsibility performance and supranational-law support regarding disclosures in the Nordic countries. Next, Lipton [77] discussed the importance of stakeholder-oriented disclosure, while Saleem et al. [76] examined the evolution of French corporate-governance law, including exposures using the collaboration approach. Mangen et al. [73] explored the content disclosed under mandatory and voluntary disclosures in the marijuana industry in Canada. One study explained why the United States still relies heavily on private ordering in managing non-financial disclosures, and suggested possible reforms [75]. This study by Ho [75] can explain more about the study by Berger-Walliser and Scott [71] that explored the norms in the United

States regarding corporate social responsibility. Lastly, Abela [74] focused on businessmodel disclosures by examining the consistency of data obtained from industry players to conceptualise business models in the literature.

Based on the literature review on disclosure approaches, one possible future study is to examine disclosure approaches of integrated reporting. A study in the South African context suggested that the mandatory adoption of integrated reporting could be the driver for potential enhanced alignment with the SDGs [7], which requires further examination from the legal aspect on other jurisdictions. In addition, a company's direction in reporting should be beneficial to the other stakeholders rather than the investors alone [78], indicating the significance of integrated reporting.

#### 4.2.4. Stakeholders' Engagement

The next theme established by utilizing the functions provided by ATLAS.ti version 9 is stakeholders' engagement as seen in Figure 8. Out of 62 articles, only two are grouped under this theme, despite its importance, which shows that this theme is under-explored [79].

**Figure 8.** Papers under the theme of stakeholders' engagement [77,79].

From 2014 to early 2021, the literature that discussed this theme started in 2020, when Lipton [77] examined the feasibility of a stakeholder-oriented disclosure approach. Next, Cosma et al. [79] studied stakeholder engagement in European banks to determine the impacts of regulations on stakeholder engagement, and expanded the study by Lipton [77] as they looked into another angle relating to stakeholders' engagement. Finally, a study highlighted the importance of stakeholder engagement in achieving the SDGs [80], suggesting vital future studies under this theme, particularly from a legal perspective. A possible future study under this theme would be to develop the study by Cosma et al. [79] to investigate the impacts of disclosure regulations on the stakeholder-engagement process in other sectors.

### 4.2.5. The Effectiveness of Regulatory Interventions

As shown in Figure 9, several papers discuss the theme of the effectiveness of regulatory interventions. These papers generally aim to investigate how effective regulatory interventions are towards the more successful implementation of social-responsibility performance and enhanced transparency of information disclosure.

**Figure 9.** Papers under the theme of the effectiveness of regulatory interventions [57,70,81–87].

One study scrutinized the efficacy of disclosures under Directive 2014/95/EU in achieving sustainability and transparency [86]. Another study explored the extent to which regulations can enhance social-responsibility performance in RMG industries using a new governance approach [81], which extended the parameter of the study carried out by Ahern [86]. Next, Haeberle [87] studied the selective-disclosure rule by the SEC that is said to cause the underproduction of corporate information, hence intending to explore one new mechanism: constructing an information market to address the issue. Georgiev [82] expanded the study by Haeberle [87] when he examined the deficiencies of SEC disclosure rules. Georgiev [82] specifically studied materiality standards that led to the underproduction of information by large companies. Bini et al. [83] examined the effectiveness of regulations on management-commentary disclosure in Italy. Nicolae [84] expanded this further, by evaluating the efficiency of the Australian Corporations Act 2001 in improving climate-change performance by companies. The study examined the synergy between the said act and the Global Reporting Initiative (GRI). Lloret et al. [85] contradicted the study objective of Nicolae [84], demonstrating that regulatory interventions in curbing greenhouse-gas emissions impair sustainable behaviour by companies in Mexico, instead of promoting them. This study by Lloret et al. [85] is unique, as it challenges the assumption that regulations could encourage sustainable corporations.

Another study in line with Lloret et al. [85] is a study by Martin [70] that investigated whether disclosure laws effectively address human-rights issues or can be manipulated to improve a company's image. Martin [70] paved the way for future studies with a more critical question on the truth of a company's disclosure. A study by Hess [57] supported the basis of the study carried out by Martin [70], as it examined the potential effect of nonfinancial information regimes on human rights issues, and highlighted several problems regarding this type of disclosure, such as selective disclosure and impression management. Therefore, based on the literature that revolved around the theme of the effectiveness of regulatory interventions, it is observed that these papers are concerned with whether disclosure regulations can effectively realize sustainability goals.

#### 4.2.6. The Impacts of Regulations

Based on Figure 10, it is unsurprising that most of the articles reviewed revolved around regulation impacts. It is only natural for researchers to investigate and examine the effects of disclosure laws on various constructs. Among the observations based on the literature review on this theme is that several studies aimed to find the relationship between disclosure regulations and the quality and quantity of sustainability reporting [27,45,61,88–94].

**Figure 10.** Papers under the theme of the impact of regulations [24,27,44,45,54,55,58,60,61,66,72,79,88–104].

For example, Zheng et al. [45] examined the association between regulation pressure and a companies' decision to report, and the comprehensiveness of the reporting. Szabó and Sørensen [88] investigated the possible impacts of Directive 2014/95/EU on the quantity of non-financial information disclosure and its consistency and comparability. Next, Venturelli et al. [5] analyzed the extent of non-financial information disclosed by Italian companies after the assimilation of Directive 2014/95/EU into Legislative Decree 254. In contrast, Mion and Loza Adaui [27] explored the effects of Directive 2014/95/EU on the quality of sustainability reporting produced by Italian and German companies. Tarquinio et al. [94] also examined Directive 2014/95/EU, looking at how it influenced the number of sustainability disclosures by Italian companies. Faisal et al. [61] studied the effects of disclosure regulations on the extent of sustainability information by companies in Indonesia, and Loza Adaui [91] studied the consequences of sustainability disclosure requirements on the quality of sustainability reporting in Peruvian companies.

A study by Tiron-Tudor et al. [90] provides fresh insight, as it analyzed the extent of sustainability disclosure by Romanian listed companies before and after implementing Directive 2014/95/EU, where most studies investigated the after-effects of disclosure regulations. A survey by Nicolò et al. [93] examined the relationship between Directive 2014/95/EU and the extent of sustainability disclosures by state-owned enterprises that issued integrated reporting; this study also provides a new perspective, as most studies do not focus on disclosures in integrated reporting.

Interestingly, while most of the literature discussed the after-effects of the introduction of disclosure regulations, Dumitru et al. [101] chose to investigate the quality of nonfinancial information by companies in Romania and Poland before the introduction of Directive 2014/90/EU. At the same time, Carini et al. [98] also examined sustainability disclosures by oil and gas companies before the introduction of Directive 2014/95/EU. These studies are of importance in assisting us to see clearly how companies change and adapt to comply with the Directive after its introduction, and whether the regulations play a significant role in ensuring sustainability-disclosure compliance by companies.

Another observation is that several studies focused on examining the impacts of sustainability-disclosure regulations on corporate behavior [45,66,92,100,102]. For example, Dong and Xu [102] explored the effects of CSR regulations on CSR disclosure practices in mining companies in China and LeBaron, and Rühmkorf [66] studied the impact of the UK Modern Slavery Act 2015 UK Bribery Act 2010 on corporate behavior. Next, Liu et al. [100] examined the effect of the Australian National Greenhouse and Energy Reporting Scheme on the voluntary disclosure of climate-change information. Finally, Guo and Yang [99] investigated the impact of SEC Guidance 2010 on corporate social-responsibility reporting. These studies chose specific regulations regarding disclosure to examine its effects on corporate practice.

Chakraborty [89] then examined the level of corporate social-responsibility performance and disclosure by banks listed on the Dhaka Stock Exchange. Jackson et al. [92] expanded the prior study by examining the effects of non-financial disclosure regulations on corporate social responsibility in 24 OECD countries. Aureli et al. [24] explored the impacts of mandatory non-financial disclosure, specifically on corporate practices of Italianlisted companies that did not disclose sustainability information before the transposition of Directive 2014/95/EU. Several studies examine a specific response from companies because of disclosure regulations. For example, Hummel and Rötzel [54] investigated the effects of the disclosure regulations on the greenhouse-gas emissions introduced under the United Kingdom Companies Act 2006 Regulations 2013 towards companies' practices. Hong et al. [104] considered how sustainability disclosure regulations affected companies' disclosures on green innovation. A study by Lu et al. [95] provides an interesting angle in examining the impact of sustainability reporting regulations on companies in China that are not subjected to disclosure regulations, as most studies investigated the effect of regulations on the subjected entities. Finally, a study by Cosma et al. [79] expanded the previous studies. It examined the impact of the introduction of Directive 2014/95/EU on stakeholders' engagement process by European banks, which the prior literature under this theme did not discuss.

Next, several studies explored the interrelation between disclosure regulations and stock value or a company's investment [60,97]. For example, Liu et al. [60] explored the impacts of sustainability reporting regulations on the stock markets of Singapore and Hong Kong, and Cordazzo et al. [97] investigated the effects of mandatory disclosure regulations on the value of non-financial information of Italian-listed companies for investors. Cousins et al. [96] then examined the impact of the United Kingdom Modern Slavery Act 2015 on stock prices. These studies signified the importance of upholding shareholders' interest in companies by prioritizing their investment returns.

A few studies aimed to investigate selected countries' reactions to the introduction of Directive 2014-95/EU. For instance, Camilleri [103] explored how some European Union member-states reacted and adapted to Directive 214/95/EU. Then, Aureli et al. [55] studied the transposition of Directive 2014/95/EU into the United Kingdom, France and Italy's legal systems using the fit/misfit theory. Next, Kinderman [105] aimed to explore governments' position, specifically France, Germany, and the United Kingdom, towards Directive 2014/95/EU, and analyzed the factors influencing their preferences and the prospect of regulatory harmonization.

From observation, a possible future study under this theme would be to expand the research by Kinderman [105] by investigating Southeast Asian countries' approaches and preferences in introducing regulations on non-financial information by companies, as most studies focused on European countries.
