The author holds a bachelor of arts degree from Brown University and graduated from Cornell Law School, after which she practiced corporate law in Manhattan at a complex-litigation firm. She recently received a master of science in nonprofit management.
On the surface it makes sense that corporations inherently conflict with the concept of corporate social responsibility (CSR). Traditionally, the basic definition of a business is to generate profits for its shareholders. CSR, at its most basic level, is the idea that businesses have responsibilities not only to their shareholders but also to stakeholders whom their business activities either directly or indirectly and therefore should create policies designed to protect the interests of stakeholders. Corporations have never been interested in embracing CSR. In 1970, the same year that the term CSR was first used, famed economist Milton Friedman stated in an interview in The New York Times Magazine that a corporation “has one and only one social responsibility — to use its resources and engage in activities designed to increase its profits so long as it stays within the rules of the game, which is to say, engages in open and free competition without deception or fraud.”
Today’s world, of course, has changed from the 1970s. Transnational corporations (TNCs) dominate the economic landscape with some of them earning more money per year than some states’ gross domestic product (GDP) and employing more foreign workers than the population of entire states. With the rise of TNCs, CSR also increased has increased in popularity as global leaders are now more concerned about the environment, sustainability, human rights, and the future of the planet as opposed to economic interests. External factors, including the 2008 financial crisis and the increased sophistication of the media, raised public awareness of corporate activities and with that increased the demand for transparency and accountability in business. While the decision to ignore CSR policies might have in the past been defensible as a business decision, today from both a business and legal standpoint it is simply foolish not to consider implementing CSR initiatives.
With a new presidential election in the near future and the world focused now on stakeholder interests, now is the moment that TNCs have the chance to control how to incorporate CSR policies into their business models. If they chose to ignore CSR altogether, soon this decision might be out be of their hands entirely.
The Rapid and Unfettered Growth of TNCs
Before the rapid expansion of businesses across the ocean in the 1990s, they were restricted to their own state borders. This limited business operations in a number of important ways. Most importantly, a business restricted to its incorporating state is subject to strict scrutiny of its operations. Labor in Western Europe and the United States is protected by a number of laws making labor extremely costly. Minimum wage and hour requirements, paid leave, requirements for overtime pay, and employer health care plans are standard in the West but are also costly for businesses. Businesses also have to work with unions to negotiate contracts, deal with safety inspectors, and pay taxes to the government. Moreover, workers are aware of their rights and also of the legal avenues to file suit if those rights are violated.
During the 1990s, third party global economic organizations, including the World Bank, the United Nations, and the North American Free Trade Agreement (NAFTA), decided that in order to encourage the growth of business, laws would be drafted to encourage the unrestricted free flow of goods, services, and capital between nations. Once trade restrictions were relaxed, the size, scope, and wealth of businesses exploded quickly. This “rapid globalization led to an “inexorable integration of markets, nation states, and technologies to a degree never witnessed before...enabling individuals, corporations, and nation states to reach around the world farther, faster, deeper, and cheaper than before, the spread of free-market capitalism to virtually every country around the world.”
No Rules to Follow So Why Follow the Rules
TNCs expanded their foreign operations into developing countries because they had limited financial capital, a weak infrastructure, were isolated from the rest of the world, and had massive populations below the poverty line in desperate need of work and willing to work in any conditions. This labor force was easily exploited given their desperate circumstances and lack of opportunities elsewhere.
Many developing countries had vast natural resources in their countries but were the subjects of UN embargoes for violating human rights. Based on the argument that they were “states” and therefore were not bound by the Universal Declaration of Human Rights, TNCs financed dictatorships by supplying them with capital and circumventing UN economic embargoes for their own personal profit.
By buying their raw materials, employing their populations, and being their own only source of financial capital, TNCs soon became de facto leaders of entire nations. They were not only able to purchase a nation’s people and raw materials but its sovereignty as well.
Dealing with Human Rights Violations
Even today, TNCs take a “reactive” approach to human rights violations abroad whereby a representative from a parent company performs damage control after an incident occurs. A reactive approach is not concerned with stakeholder interests and does not address the underlying source of the harm. The goal of this approach is protecting the reputation of the company by preventing news of the incident from leaking to the public. How the company deals with incidents varies but the goal is to pay as little as possible to get the parties involved to sign nondisclosure agreements (NDA) legally binding them to silence.
Conversely, a preventative approach is aligned closely with CSR. It emphasizes the idea that investing money in worker safety, better working conditions, training, sustainable materials, and other initiatives before problems arise creates a better working environment, avoids problems or litigation, and creates a loyal and better trained work force. A preventative approach is rooted in the belief that a business can both maximize profits and protect stakeholder interests.
Complex Jurisdictional Issues
For years, TNCs have occupied a gray area outside international law. Given their expansive size, complex levels of subsidiaries, millions of employees, and thousands of projects, untangling these levels to find the parent company at the top is a Gordian knot so complex even Alexander the Great would have difficulty unraveling it. Now it is often the case that laborers are unaware whom they are actually working for or the project for which they are working only on a small part.
Even more disturbing is that a parent company is often unaware to whom they contracted out important projects. There have been incidents in which a parent company will contract a job to a supplier and without notifying the parent, that contractor will in turn contract this job to a sub contractor who is cheaper. Of course, the sub contractor is cheaper because its work is defective or it engages in unethical business practices and in the end, the product, which by now has been mass produced around the world, must be recalled. It is astonishing that corporations who have such vast wealth also have such little oversight over their own operations. They are like the ancient Greek and Roman Empires, ruling from an ocean away with little thought as to what occurs after they have sent out their instructions and no real knowledge of the faceless and replaceable laborers who are working day and night on their projects.
Moreover, just like the empires of old who discouraged uprisings of any kind, on the rare occasions that labor manages to voice their grievances, it usually results in when they have torture, imprisonment, exile, or death.
Comparing United States Based TNCs to Those Based in Europe and Asia
A logical assumption to make is that United States based TNCs would be more likely to institute laws protecting labor because for years the United States has had strong laws in place protecting labor and a strong legal precedent for holding corporations liable. This is not the case.
Despite laws protecting labor in the United States, corporations still feel strongly that business is a private enterprise whose sole purpose is to generate profits. Europe and Asia take a more integrated view of business, seeing it performing the dual role of generating a profit for its shareholders and having a “shared responsibility [with the government] to advance society’s interests and concerns.”
Even though the United States continues to hold the position as the world’s wealthiest country, its advantage now is not nearly as great as it was a decade ago. The financial crisis of 2008 demonstrated the weakness of the capitalist economic system and the economies of Europe and Asia have rebounded faster than that of the United States because of government stabilization.
Even though U.S.-based TNCs are still not accepting of CSR policies, they now realize that having the reputation of a “CSR friendly” corporation is of value to today’s consumer. Instead of simply implementing CSR initiatives many TNCs are instead designing a PR strategy around philanthropic and charitable endeavors and labeling it CSR to confuse the general public into believing that they are “CSR friendly.” CSR is an investment in the workers and business model of one’s own company to effect change in one’s own business. Philanthropy is a donation of money or time to an unrelated cause.
Corporate Liability: Addressed but Not Answered
For years, company attorneys were confident that even if a foreign plaintiff were able to file suit against a parent company for a tort committed by its subsidiary, no federal court would grant that plaintiff jurisdiction. That changed, however, when an enterprising legal team dusted off a statute not used since 1789 getting jurisdiction for his foreign client for a tort committed abroad .
Dolly Filártiga, a political refugee from Honduras, filed a claim against the Inspector General of Paraguay, for the murder and torture of her son in Paraguay, using the Alien Tort Statute (ATS. On appeal from the Eastern District of New York, The Supreme Court ruled that “for purposes of civil liability, the torturer has become like the pirate and slave trader before him hostis humani generis, an enemy of all mankind’ and that ‘whenever an alleged torturer is found and served with process by an alien within our borders, § 1350 provides federal jurisdiction.’'
Despite a clear indication that the ATS could demonstrate jurisdiction, there was only 31 reported cases filed under the ATS between 1980 and 2004.
The Supreme Court got involved in ATS litigation to define the limits of the ATS when it ruled on Sosa v. Álvarez-Machain et al. Sosa was a DEA agent who was tasked to extradite from Mexico a suspect accused of torturing and killing two DEA agents. Unable to extradite him, Sosa hired two Mexican nationals to kidnap him; he then stood trial, where the suspect was acquitted. Later, Sosa was put on trial for arbitrary detention and arrest and a judgment was entered against him in the Ninth Circuit. The Supreme Court accepted the case on the issue of whether the ATS creates private causes of action for torts committed anywhere, in violation of international law or treaties with the United States, or whether it is instead merely a provision that grants jurisdiction to federal courts.
The Court found that although the ATS is a jurisdictional statute, it was intended to have a practical effect. The Court concluded that it “ is best read as having been enacted on the understanding that the common law would provide a cause of action for the modest number of international law violations with potential for personal liability at the time.” Rather than enumerating specific international norms which would give rise to causes of action, the Court set forth a standard which recognized the evolving nature of international law and provided a modern framework for determining whether a tort constitutes a cause of action under the ATS; this framework incorporates the features of universality, obligatory nature, specificity and prudential considerations . Since arrest and arbitrary detention did not violate any treaty with the United States; nor did the arrest and detention violate an international norm meeting the “specific, universal and obligatory” standard, the case against Sosa was dismissed.
The 2013 Supreme Court holding in Kiobel v. Royal Dutch Petroleum was relevant for its procedural posture more than its actual verdict. Nigerian plaintiffs alleged that The Royal Dutch Shell Company compelled its Nigerian subsidiary and the Nigerian government to brutally crush a peaceful resistance movement protesting aggressive oil development. The defendants moved to dismiss, arguing (1) that customary international law itself provided the rules by which to decide whether conduct violates the law of nations where non-state actors are alleged to have committed the wrong in question and (2) no norm ever existed between nations that imposes liability upon corporate actors.
In 2010, the SDNY found for the defendants, holding that (1) corporations cannot be held liable for violations of customary international law and that the scope of liability is determined by customary international law itself and (2) under Supreme Court precedent, the ATS required courts to apply norms of international law—and not domestic law—to the scope of defendants' liabilities. Trying to reconcile a circuit split, The Supreme Court accepted the case to decide “whether corporations are immune from tort liability for violations of international law.”
After presented oral argument and the submission of amicus briefs, the Court remanded the case to the attorneys for further argument on an entirely new legal issue: ‘Whether and under what circumstances the Alien Tort Statute, 28 U.S.C. § 1350, allows courts to recognize a cause of action for violations of the law of nations occurring within the territory of a sovereign other than the United States.”
Defendants invoked the “presumption against extraterritoriality,” stating that the territorial reach of the ATS should be limited since the statute does not state explicitly it applies to conduct outside the United States and further to rule on the matter would violate state sovereignty.
While the U.S. Government originally supported the Kiobel plaintiffs on the issue of corporate liability, the briefs submitted in the second round were more divisive. The Justice Department argued that The Supreme Court refused to recognize ATS suits that “challenged the actions of a foreign sovereign in its own territory” where “foreign plaintiffs are suing foreign corporate defendants for aiding and abetting a foreign sovereign’s treatment of its own citizens in its own territory.” The brief further argued that the executive branch play a stronger role in determining whether the ATS applies to violations committed overseas, on a case-by-case basis because this way judges are able to detect when the primary human rights abuser is physically present in the United States and detain them which best serves U.S. foreign policy interests in denying safe haven to violators of human rights. Both the Justice and State Departments agreed that The Supreme Court continue to allow extraterritorial ATS suits to continue if the plaintiff could demonstrate jurisdiction.
The Supreme Court affirmed the SDNY’s verdict but avoided the issue of corporate liability thus making the events leading up to the opinion more important than the verdict itself. Justice Breyer, writing for the majority of the Court, held that [plaintiffs’ claims fail because] “ATS claims rest on conduct that occurred outside the United States, those claims must “touch and concern the territory of the United States . . . with sufficient force to displace the presumption against extraterritorial application.” The Court reasoned that the defendants’ conduct occurring outside the United States indicated no more than a “mere corporate presence” and did not sufficiently “touch and concern” the United States to displace the presumption against extraterritoriality. For all intents and purposes, The Supreme Court avoided an actual legal ruling on this case by first restating a basic premise of civil procedure and then, even avoiding the opportunity to provide guidance to circuit judges on (1) factors to use to determine level of corporate presence in the forum state and (2) factors to use in determining if the level of conduct rises to that which “touches and concerns” the United States. Thus, each ATS case remains a matter of first impression for circuit judges.
Initially, the 2014 holding in Daimler AG v. Bauman reversing the Ninth Circuit seemed as though The Supreme Court finally had ruled in favor of corporate interests but upon closer examination the reality is that the Court’s legal reasoning is sound and based on established precedent. In this case the plaintiffs simply did not prove jurisdiction.
The issue presented was whether a U.S. court had the authority to hear a case against a foreign corporation "solely on the fact that an indirect corporate subsidiary performs services on behalf of the defendant" in the state where the lawsuit was filed.” Plaintiffs worked at a Argentinian subsidiary of Mercedes-Benz, a wholly owned subsidiary of Daimler and alleged that when they tried to unionize, management, with the help of police and military, tortured and threatened them. The Ninth Circuit reversed the District Court finding personal jurisdiction under an “agency theory.”
In an unanimous decision, The Supreme Court upheld the District Court’s verdict, holding (1) that DaimlerChrysler’s wholly owned subsidiary Mercedes-Benz USA was not an agent of its owner, therefore it was unreasonable to exercise personal jurisdiction directly over DaimlerChrysler and (2) that “sizable” sales in a forum state was not enough to rebut the theory of extraterritoriality because corporate sales in a forum state is not sufficient to prove defendant’s presence “touched and concerned” the forum state or that it rose to the level of a “corporate presence”.
The Future of TNCs
Currently, TNCs control approximately 16% of the entire world’s productive assets and employ over 73 million global citizens. The market value of the wealthiest TNCs is worth hundreds of billions of dollars on the global exchange. Apple Inc., the richest TNC to date, is listed on the global price indices at $725 billion. United States based TNCs control around 40% of that wealth. TNCs were able to accumulate vast wealth rapidly because of relaxed regulations and lack of oversight. However, now focus has shifted away from economic expansion to emphasis on stakeholder interests, sustainability, and concern for the environment.
Third party global governance organizations are not interested in grating TNCs free range in their behavior any longer. Task forces are forming around the world to address holding them accountable for their misconduct.
In 2001, The United Nations created a specialized committee whose sole purpose was to hold TNCs accountable for human rights violations by extending the authority to sanction to the European Court of Human Rights or creating an entirely new international court specifically designed to hear human rights abuses committed by TNCs.
Soft law exists specifically governing the behavior of TNCs and more is being drafted every day by third party global governance organizations. In 2003, The United Nations Norms on the Responsibility of Transnational Corporations and Other Business Enterprises with Regard to Human Rights was drafted as a precursor to what will one day be enforceable international law governing the behavior of TNCs as they relate to contracting with developing nations and ethical business practices. The Global Compact, a voluntary corporate citizenship initiative whose signatories commit to basic principles of sustainability, is publically available. Companies who do not sign the Compact are therefore noticed and their business practices are immediately questioned.
Despite continued equivocation by many TNCs to embrace CSR as part of their business agenda, there is now real data showing that corporations who implement CSR initiatives also generally increase their profit margins. Thus, the real resistance to CSR now is no longer that it will affect profit but simply a resistance to change. If history has taught us anything it is that nothing is permanent. In 1938, the British Empire covered 13.01 square miles of the Earth or 22% of the earth’s land and it reigned over 20% of the world’s population. Today, that empire is 93,800 square miles and has 64.5 million people. If TNCs want to remain dominant in today’s changing society, they must adopt to the new priorities of that society. As Benjamin Disraeli said, “In a progressive country…change is inevitable.”
 See Goddard v. Chaffee, 2 Allen (Mass.) 305, 79 Am. Dec. 796; Sterne v. State, 20 Ala. 46) (1861).
 A company’s stakeholders are individuals or groups who are directly impacted by the business’ operations and decisions and can be either potentially benefitted or harmed by the decisions the business makes. See Carlson, J.R., Carlson D.S., & Ferguson M. (2011); See also “Deceptive Impression Management: Does Deception Pay in Established Workplace Relationships?” Journal of Business Ethics,100(3), 497-514 (2010).
 See Milton Friedman, "The Social Responsibility of Business is to Increase its Profits", The New York Times Magazine, (Sept. 13, 1970.)
 See Danailov, Sylvia, “The Accountability of Non-State Actors for Human Rights Violations: the Special Case of Transnational Corporations,” at 45 (Geneva, October 1998) (citing studies to show the enormous wealth and power of TNCs today).
 See generally Community Legal Education Center White Papers, “New Findings on Conditions Across
Wal-Mart’s Garment Supplier Factories in Cambodia, India, and Indonesia,” Society for Labor and Development, India, 19 (May 2015) (discussing a culture denying “freedom of association” to all factory workers, the punishment and torture of pro-worker groups, and enforced intimidation techniques used to silence workers from organizing.)
 United States. Http://www.dol.gov/dol/topic/wages/. Cong. Bill. N.p. Web.
 The most important of these laws was The General Agreement on Tariffs and Free Trade (GATT).
 See Id. at 6 quoting Milton Friedman.
 See Danailov, Sylvia, “The Accountability of Non-State Actors for Human Rights Violations: the Special Case of Transnational Corporations” (October 1998).
 See The United Nations. Universal Declaration of Human Rights. 1948 (The Universal Declaration of Human Rights is a compromise in that in exchange for promising to further the principles and practices of human rights (and thereby giving up some aspects of self-rule), signatories are guaranteed certain privileges and protections as members of the United Nations.)
 See generally Masshiro, Miyoshi, “Sovereignty and International Law, Sovereignty, Territory & International Law (April 2014); See also Ozden, Melik, “Transnational Corporations and Human Rights,” European Third World Centre (Geneva 2006) (discussing various transnational corporations who, in direct contravention of United Nations policy, contracted with countries who had violated human rights laws to buy materials or contract for foreign labor simply for their own economic gain including Nestle, Chiquita, Dow Chemical Corporation, Standard Fruit, Dole Food, Parmalat, and Union Carbide and have not been held accountable for their actions).
 See generally John M. Conley & Cynthia A. Williams, “Engage, Embed, & Embellish: Theory versus Practice in the Corporate Social Responsibility Movement”, 31 J. Corp. 1,1-2 (2005).
 See Id.
 See Osman & Recep Yucel, “Globalization of Markets, Marketing Ethics and Social Responsibility,” International Journal of Tech Engineering, 10(5) (2010).
 See Story, Louise. "Lead Paint Prompts Mattel to Recall 967,000 Toys." The New York Times. The New York Times, 01 Aug. 2007. Web. 12 Sept. 2015 (discussing breakdowns in supply chains in China whereby original suppliers contracted with sub contractors in China to paint toys without notifying parent companies resulting in toxic toys and the need for a complete recall of toys in the United States. Mattel and RC2 (the maker of Thomas Train Engines) were affected.); See also Strom, Stephanie. "A Sweetheart Becomes Suspect; Looking Behind Those Kathie Lee Labels." The New York Times. The New York Times, 26 June 1996. Web. 12 Sept. 2015 (discussing the 1996 controversy surrounding Kathie Lee Gifford’s shock when she discovered that the clothing line she designed for Wal-Mart was being mass-produced in Honduras by children working in sweatshops) .
 See generally Community Legal Education Center, New Findings on Conditions Across Wal-Mart’s Garment Supplier Factories in Cambodia, India, and Indonesia, Society for Labor and Development, 19 (2015) (describing corporate policies denying freedom of association to workers attempting to organize, instances of torture, disappearance, exile, and murder to those who attempt to file grievances concerning their working conditions, and a corrupt system whereby unions are stacked with management so that workers continue to get no say but it appears that they are represented to the outside world); See also Hough, Phillip A., “A Race to the Bottom? Globalization, Labor Repression, and Development by Dispossession in Latin America’s Banana Industry,” Global Labor Journal, Vol.3, No.2 (2012) (After attempts to unionize in Colombia, Nicaragua, Belize, and other Latin American countries in order to peacefully request a living wage, paramilitary forces were brought out, workers were summarily executed, others were forced into exile without being allowed to tell their families farewell, and others were beaten to death.); Report of the International Commission for Labor Rights. (2013); Merchants of Menace: Repressing workers in India's new industrial belt, Violations of workers' and Trade Union Rights at Maruti Suzuki India Ltd. (In India in 2012, dozens of workers were first detained without charge and summarily fired without severance after it was discovered their membership in a trade association.) The workers rioted (without any weapons) which resulted in the arrest of over two hundred workers and a fire at the plant and the dismissal by management of over two thousand laborers, thousands of whom had never been affiliated with any organized union.
To date, over two hundred workers are still in police custody and have yet been granted access to counsel).
 See generally Pembina Consolidated Silver Mining Co. v. Pennsylvania, 125 U.S. 181 (1888) (holding the Fourteenth Amendment, forbidding a State to deny persons equal protection under the law, applies to private corporations as well as to individuals, public agencies, and the government); See also Trustees of Dartmouth College v. Woodward, 17 U.S. 518 (1819) (holding corporations may contract with other parties and sue or be sued in court in the same way as natural persons or unincorporated associations of persons).
 See Id. at 47.
 See Naeem, Farukkh. "CSR: Good Business, or PR Ploy?" Kippreportcom. N.p., 29 Mar. 2010. Web. 12 Sept. 2015.
 See Id.
 The Alien Tort Statute (ATS), 28 U.S.C. § 1350, enacted as part of the Judiciary Act of 1789 and originally intended by the Framers was created to assure foreign governments that the U.S., as a fledgling nation, was partially to prevent and provide remedies for breach of customary international law concerning diplomats and merchants.
 See Filártiga v. Peña-Irala, 630 F.2d 876, 9, 11 (2d Cir. 1980).
 See Ku, G. Julian, “The Third Wave: The Alien Tort Statute and the War on Terror, 19 Emory Int’l L. Rev. (2005).
 542 U.S. 692 (2002).
 See Id.
 See Id.
 See Id. at 31-33.
 See Kiobel v. Royal Dutch Petroleum Co., 621 F.3d 111 (2d Cir. 2010), cert. granted,
132 S. Ct. 472 (Oct. 17, 2011) (No. 10-1491).
 See Id.
 See Kiobel v. Royal Dutch Petroleum Co., 621 F.3d 111 (2d Cir. 2010)
 See Kiobel v. Royal Dutch Petroleum Co., 621 F.3d 111 (2d Cir. 2010), cert. granted,
132 S. Ct. 472 (Oct. 17, 2011) (No. 10-1491) at 2.
 See Id.
 See Brief for Royal Dutch Petroleum, Kiobel v. Royal Dutch Petroleum, 621 F.3d 111, Respondents’ Brief.
 See Brief for Royal Dutch Petroleum, Kiobel v. Royal Dutch Petroleum, 621 F.3d 111 Amici Curiae Supporting Respondents.
 132 S. Ct. 472 at 2.
 See Id.
 Although ATS filings continue, the only case to make it past the motion to dismiss stage since Daimler is Mwani v. Laden, 417 F.3d 1 (D.C. Cir. 2005), 947 F. Supp. 2d 1 - 2013 (Kenyan plaintiffs survivors of the 1998 embassy bombing in Nairobi filed claim against terrorist organization and state government; Court found that activities clearly “touched and concerned” the United States to rise to a level that jurisdiction was appropriate).
 Daimler AG v. Bauman, 134 S. Ct. 746 (2014).
 See Id.
 The Court relied on the established precedent set forth in International Shoe v. Washington, 326 U.S. 310 (1945) for the established precedent that a “state may exercise “state may exercise personal jurisdiction over an out-of-state defendant, so long as that defendant has "sufficient minimum contacts" with the forum state, from which the complaint arises.”
 See Danailov, Sylvia, “The Accountability of Non-State Actors for Human Rights Violations: the Special Case of Transnational Corporations,” (Geneva, October 1998) (citing studies to show the enormous wealth and power of TNCs today).
“Market value” is the share price times the number of shares outstanding. Listed companies do not include investment companies, mutual funds, or other investment vehicles.
Definition provided by The World Bank,
 See Danailov, infra, at 47.
 See Id.
 See John Ruggie, "United Nations Guiding Principles on Business and Human Rights", March 21, 2011
 See “UN Norms on the Responsibility of Transnational Corporations and Other Business Enterprises with Regard to Human Rights,” UN Doc. E/CN.4/Sub.2/2003/12/Rev.2 (2003) of August 26, 2003.
 See Hoessle, Ulrike: The Contribution of the UN Global Compact towards the Compliance of International Regimes: A Comparative Study of Businesses from the USA, Mozambique, United Arab Emirates and Germany. In: Journal of Corporate Citizenship, Volume 2014, Number 53, March 2014, pp. 27-60(34).
 See Naeem, Farukkh. "CSR: Good Business, or PR Ploy?" Kippreportcom. N.p., 29 Mar. 2010. Web. 12 Sept. 2015.