Regulatory perspective for deepening CSR disclosure practice in Nigeria

The purpose of this study is to assess the need for a regulation of Corporate Social Responsibility (CSR) disclosure practices of listed non-financial sector entities in Nigeria. Survey research method was adopted in the study. Information gathered from the primary source (questionnaire) was used to test the users’ perception on the need for a regulated practice in Nigeria. Both Content Validity and Cronbach’s Alpha (α) were used to test the validity and reliability of the research instrument respectively. The Cronbach’s Alpha showed an appreciable level of reliability of 0.851. Results of pairwise comparison showed that both the regulators and management group agree on the need to regulate CSR disclosure practice while the opinions of the other groups (academics, information intermediaries and investors) varied significantly. The two hypotheses constructed in the course of the study tested the perceptions of the users on the need for a CSR disclosure regulation. Findings based on an ANOVA analysis of the users perceptions revealed that a voluntary CSR disclosure practice might not be effective enough in curbing the inadequacy of CSR disclosures of these entities and as such there might be a need to regulate the practice. The paper exposes the mind of users of accounting information on their understanding of the level of CSR disclosure practices of listed non-financial sector entities in Nigeria and their demand for a more regulated system of CSR disclosure practice. There is currently no research assessing how CSR disclosure practices of listed non-financial sector entities in Nigeria can be improved. It is expected that the study will promote a movement for curtailing the haphazard preparations of CSR information in Nigeria.

It has been observed that research into the concept of CSR is relatively recent in Nigeria.Studies in Nigeria showed that corporate entities are doing less than expected in CSR and CSR disclosure (Uadiale and Fagbemi, 2012).
Although there exists researches that have looked into the importance of regulating CSR practices of financial institutions (Achua, 2008;Sholtens, 2009), Petroleum Industry (Ihugba, 2012) and Multinationals (Amao, 2008), the importance of regulating CSR disclosure practices of non-financial sector entities as a group in Nigeria has not earned significant attention.This need comes at a time when there is agitation for companies to pay attention to emissions reductions, community welfare and living condition of the people.The quest for universally acceptable and understandable financial statements also prompted the need for a study like this.
This study tested two hypotheses on the perception of users of accounting information on the need to regulate CSR disclosure practice of listed non-financial sector organizations in Nigeria.It investigated the voluntary CSR disclosure practices of listed non-financial sector organizations in Nigeria to determine the need for regulation of the practice or otherwise.The essence of the study is to promote improvement in the quality of CSR reports and encourage consistency, transparency and accountability in CSR reporting most especially among non-financial entities in Nigeria.The research has focused on non-financial sector entities firstly, considering the peculiarity of their activities in terms of its impact on the local communities, health and safety of employees and communities, the ecosystem and other socially responsible activities; as opposed to the financial sector entities whose activities have little impact on the ecosystem, environment, or local communities.Special interest has also been drawn to these non-financial sector entities since they constitute more than 65% of the companies on the main board of the Nigerian stock market (the Nigerian Stock Exchange, 2013).Admittance of Companies to the main board is based on profitability or market capitalisation.Listed companies have been specifically considered because according to the Nigerian Stock Exchange website, these categories of companies are usually expected to maintain high standard of disclosure, transparency and integrity.

Problem analysis
Though CSR disclosure practice is a voluntary activity in Adeyemi and Ayanlola 271 Nigeria, it is often alleged that listed companies do not fully comply with the disclosure practices stipulated by regulatory agencies (Akhtaruddin, 2005).Accounting reports of Nigerian companies have been found to be deficient over time (Adeyemi, 2006).It appears that CSR disclosure practice in Nigeria is unregulated.Although the introduction and adoption of IFRS in Nigeria is aimed at increasing the level of accounting information disclosure, it appears that CSR disclosure level is low.The implication is that Nigerian firms, especially non-financial sector organizations, may likely abuse the weaknesses of voluntary CSR disclosures and as such it becomes imperative to ascertain the need to regulate or not to regulate the practice since the activities of these categories of entities tend to have significant impact on the wellbeing, and environment of the people.
This research is a contribution to previous research that documented the level of voluntary CSR disclosure practices of non-financial sector entities in Nigeria (Adeyemi and Ayanlola, 2014).The study therefore seeks to provide suggestive answers to the inadequacies, inconsistencies and lack of transparency in reporting CSR, which we have identified as been associated with voluntary CSR disclosures in Nigeria.

Aim and objectives of the study
The aim of this study is to assess the need for a regulation of CSR disclosure practice of listed nonfinancial sector companies in Nigeria.The specific objectives for achieving this aim are to: a. assess how users of accounting information perceive the level of voluntary CSR disclosure of non-financial sector organizations in Nigeria.b. explore the rationale for regulating CSR disclosure in Nigeria.

Research questions
The research objectives are guided by the following research questions: a. How do users of accounting information perceive voluntary CSR disclosure practices of non-financial sector organizations in Nigeria? b.To what extent can regulation improve CSR disclosure practices of non-financial sector organizations in Nigeria?c.How can the level of CSR disclosure practice of nonfinancial sector organizations in Nigeria be improved?

Research hypotheses
Two (2) hypotheses were formulated for the study so as to achieve the research objectives i and ii.The research hypotheses stated in null form (Ho) are the following: H o 1 : There is no significant difference in the users of accounting information's perception of the level of voluntary CSR disclosure in Nigeria.H o 2 : There is no significant difference in the users of accounting information's perception of the need to regulate CSR disclosure practices in Nigeria.

Significance of the Study
It has been identified that several groups have vested interest in a business organization (Glautier et al., 2011).The study will therefore be of significance to the government, investors, business managers, regulatory bodies, educators, researchers, accountants, auditors and scholars in the field of accounting as well as standard setters.Researchers will benefit from the research work in that it will shed more light on the CSR disclosure practices of most non-financial sector concerns in Nigeria which would be of more advantage to them.

Scope/limitation of study
This study only assesses users of financial information's perception on the need for a CSR disclosure regulation of listed non-financial sector entities in Nigeria.

General review
Corporate entities, just like every other citizen; most importantly listed companies are expected to be socially responsible and accountable for their social actions.In essence, they should show commitment towards ensuring that the immediate environment in which they operate feel the positive impact of their activities.It seems corporate organizations now understand the importance of giving back to the society by incorporating CSR as part of their strategic management decisions.In Nigeria, this practice has been on a voluntary basis.Corporate social responsibility could be viewed as the duty of care to give back to the society such supports (which could be in the form of contributions towards educational development of the people of the area, provision of infrastructural facilities like pipe borne water, contribution towards rural electrification projects, road construction, reducing Green House Gas emissions, promoting sustainable energy consumption, and so on. Most companies these days disclose their CSR activities depending on the jurisdiction in which they operate.In Germany for instance, companies are not bound by any regulation to disclose CSR information and therefore such disclosures are voluntary (Gamerschlag et al., 2011).While, other European countries such as the United Kingdom, France, and the Netherlands have some specific guidelines or practices for the provision of CSR information (Kolk et al., 2001).
The history of formalized CSR in Nigeria has been traced to the CSR practices in the oil and gas multinationals which mainly focused on remedying the effects of their extraction activities on the local communities (Uadiale and Fagbemi, 2012).There have been several studies assessing CSR practices in Nigeria.Uwuigbe and Uadiale (2011), based on their study, identified that CSR disclosure practice in building and materials industries was still at its early stage.A similar Kenyan study by Ponnu and Okoth (2009) on CSR disclosure of listed companies on the Nairobi Stock Exchange revealed that CSR disclosure received only modest attention and the theme most commonly disclosed was community involvement.Some researchers have carried out studies on the need to regulate CSR disclosure practices.Sholtens ( 2009) carried out a study on the need to regulate CSR practices in the international banking industry by attempting to develop a framework for assessing CSR of these categories of institutions.Though it seems the practices have improved by applying the framework to just 30 firms, the author was still able to identify that CSR is very important to the growth, survival and performance of the sampled banks and as such the need for their regulation cannot be overemphasized.Constantina (2003) analyzed the role the government plays in promoting socially responsible behavior.Based on the study it was observed that companies under government regulations tend to exhibit ethical business behavior and act in a socially responsible manner than others.
According to a study by Frynas (2012), "voluntary environmental reporting raises questions about the reliability of self-reported company data."In the same study, Instances were given in the case of BP sustainability report 2006 that reported 417 Oil spills in 2006 and still reported 300 for the same year in 2010; similar instances were given for Simopec (the largest oil company in China) and Russia's Lukoil company.Claims in the study suggest that voluntary environmental reporting raises questions about comparability.In Nigeria, Achua (2008) agitated for the prioritization of corporate social responsibility (CSR) as the foremost condition for banking stability reforms.According to the author, though self-induced vices, regulatory laxity, inauspicious macroeconomic environment, and endemic corruption in the economy are major constraints to the discharge of CSR in the Nigerian banking system, external regulation will have to be blended with conscious self-regulation by the banking institutions for any CSR reform to be effective.Amao (2008) explored the legal and institutional framework for the control of CSR practices of Multinational corporations (MNCs) in Nigeria.The study explored various aspects of company law and human rights law and argued that although CSR practice is becoming well entrenched in Nigeria, we cannot rule out the importance of a domestic framework for the regulation of Multinational corporations (MNCs).The author further identified areas of the Nigerian law that needed reform in order for a proper regulation to address the challenges raised by poor CSR practices.Ihugba (2012) observed that in Nigeria, CSR as a voluntary practice was no longer attainable particularly in the petroleum industry and suggested the need to introduce compulsory regulation into corporate governance via the Nigerian Extractive Industry Transparency Initiative (NEITI) Act 2007.
On the other hand, some scholars criticized the need for a CSR regulation in developing countries.For instance, Reinhardt et al. (2008) indicated that the regulation of CSR is a form of legalizing 'profit-sacrificing behavior'.Their arguments is that there is no point regulating CSR when regulations can often go unenforced owing to weak legal institutions (e.g., a corrupt judiciary).As such "those laws governing CSR and the degree to which those laws are enforced may vary substantially across developing countries" (Reinhardt et al., 2008).

A brief review of the Nigerian economy and its regulatory environment
Nigeria is a country with a population estimated at 168.8 million (2012 figure), Africa's most populous nation.It has been described by the World Bank (2012) as one of the fastest growing economies in the world, with a Gross Domestic Product (GDP) growth rate of about 7 percent in 2012.The country's GDP of US$262.6 billion (2012 figure) ranks Nigeria's economy the second largest in Africa and 41st in the world (World Bank 2011).According to Onuba and Abioye (2014) Nigeria is now Africa's biggest economy with a nominal GDP of US $510 billion (2013 figure) which ranks it 26th globally.Nigeria is a country richly endowed with abundant natural resources, notably oil.The country being a member of the Oil Producing and Exporting Countries (OPEC) is the World's 8th largest oil-producer, 6th largest oil exporter and a nation with the world's 6th largest deposit of gas (World Bank, 2011).According to the World Bank report, though the economy remains predominantly rural and agrarian, agriculture accounts for the largest share of its economic output.
The Nigerian regulatory environment is characterized by several regulatory bodies, agencies and statutes/Acts.Three major regulatory agencies and two self-regulating

Major regulatory bodies in Nigeria
The Financial Reporting Council of Nigeria (FRCN) The FRCN (formerly, Nigerian Accounting Standards Board (NASB)), with the enactment of the NASB Act 2003, now has statutory legal backing.The World Bank (2011) observed that FRCN lacks adequate resources to fulfill its mandate reason being that as a government agency it has relied on government subventions and has been exposed to serious budgetary constraints that hinder its performance.Despite the shortcomings of the FRCN, the institution remains a force to reckon with in a push for a regulated CSR disclosure practice in Nigeria.

The Corporate Affairs Commission
The mechanism for monitoring and enforcing requirements on accounting and financial reporting is provided for in the CAMA 1990.The CAMA empowers the Registrar of Companies i.e., the Corporate Affairs Commission (CAC) to monitor compliance with its financial reporting and disclosure requirements.Shortcomings of CAMA 1990 identified by the World Bank report are: (i.)Though the Act requires most companies to file their records with the CAC within 42 days of conclusion of the annual general meeting (AGM), in most cases, despite penalties for noncompliance, many companies do not comply with the deadlines while some do not file at all.(ii.)The audit committees' capacity to review, monitor reporting remains largely unknown.(iii.)The CAMA is outmoded regarding penalties for noncompliance (World Bank, 2011).Despite the frailty of this Act, it is an important statute to be considered in establishing a regulated practice of corporate social responsibility disclosure.

The Securities and Exchange Commission (SEC)
Securities  2011).Nevertheless the SEC is still an important regulatory body to be considered in ensuring an improved CSR disclosure practice among listed firms in Nigeria.

The Nigeria Stock Exchange (NSE)
The Nigeria Stock Exchange on behalf of SEC, review submissions by companies for compliance with the listing requirements, which include accounting standards and disclosure requirement under CAMA.The audited financial statements of listed companies in Nigeria are only published after approval of the Nigerian Stock Exchange.In addition to its responsibilities, the NSE issues sanctions for non-compliance with the requirements of the Act by way of delisting.According to the World Bank (2011), the Nigeria Stock Exchange does not have any monitoring and enforcing mechanism with respect to accounting and disclosure requirements.
According to its report, NSE monitoring efforts are primarily focused on tracking timely issuance and filing of the financial statements.Even with these efforts there are companies with overdue filing of financial statements.Despite these shortcomings identified by the World Bank, the NSE should not be displaced in an attempt to encourage CSR disclosure among listed firms in Nigeria.

Self-regulating professional accounting bodies
The statutory frameworks for the accounting profession in Nigeria include the Institute of Chartered Accountants of Nigeria (ICAN) and the Association of National Accountants of Nigeria (ANAN).The two bodies are charged with the responsibility of producing professional accountants in Nigeria.According to Belkaoui (1983) "a well-developed accounting profession and system of accounting education in a given country lead to a tradition and/or effort of providing better reporting and disclosure".
In essence, these two self-regulating bodies should not be sidelined in the effort to ensuring CSR disclosure practice.

THEORETICAL FRAMEWORK
The current study was anchored on two theories, namely, contingency theory, and legitimacy theory owing to their consistency with CSR disclosure practice.

Contingency Theory:
The contingency theory emerged as a framework to help explain choice, and adaptation and their effects on firm success (Ruschak, 2008).
Following the publication of Lawrence and Lorsch's Organization and Environment (1967) and Thomson's Organization in Action (1967), Jay Galbraith applied the Contingency theory to his study of strategic implementation of 1973.Lawrence and Lorsch argued that the amount of uncertainty and rate of change in an environment impacts the development of internal features in organizations.
Following the Dictionary of Human Resources Management (cited in Ruschak, 2008), the contingency theory suggests that the effectiveness of an organisation depends upon managers taking into account various factors that can have a negative or positive impact on the organisation.The main contingency factors identified are the environment, technology, size, product diversity and the people employed.
Contingency theory is therefore relevant to the study because it addresses the influence of contingent factors such as firm size, structure of audit committee the organisation and other financial and non-financial factors that could influence CSR disclosure practices.

Legitimacy Theory:
The development of Legitimacy theory could be traced to Prabhu et al., (cited in Anbumozhi et al., 2011).The theory posits that business entities as a matter of importance consider the rights of the community at large and not just that of its investors.Neu et al. (1998) argued that it is often easier to manage an organization's image creation through environmental information disclosure.Image creation in this context implies: (i) attempting to educate and inform the relevant public about recent corporate actions that remedy previous deficiencies; (ii) attempting to change the perceptions of other external stakeholders; and (iii) attempting to deflect attention from the perceived problem areas by changing the focus of the external public.Legitimacy theory therefore was described by Dowling and Pfeffer (cited in Deegan, 2002) as "a condition or status which exists when an entity's value system is congruent with the value system of the larger social system of which the entity is a part."When a disparity, actual or potential exists between the two values (that is an entity's value system and social value system), then there is a threat to the entity's legitimacy (Deegan, 2002).In essence therefore, organizations seek to legitimize their existence to society by voluntarily disclosing social and environmental information in a range of media (Cho and Patten, 2007;Deegan and Gordon, 1996;Wilmshrust and Frost, 2000).Legitimacy theory is considered for the study because it posits that every organization should seek to evaluate their actions and see if it is in line with the norms, values and the belief system of the society.In essence, an organization will be considered legitimate if it follows socially acceptable objectives and expectations, in a socially acceptable manner.

Conceptual model
A conceptual model was fitted for the study to explore the need for a regulated CSR disclosure practice.A lever system is used to explain the model showing clearly the three (3) important components of a typical lever system: The Load, Effort and Fulcrum (or Pivot).The load represents the perception of the users of financial information.The effort represented by the arrows, shows the level of pressure, force and or need exerted by the users of financial information for a regulated CSR disclosure practice while the fulcrum or pivot is CSR disclosure practices.
This model represented with the use of a lever system as shown in Figures 1 and 2 reflects the positive and negative perception of users of financial information on the need to regulate CSR disclosure practice.Figure 1 depicts that when the perception of users of financial information on the need to regulate CSR disclosure practice swings to the left (i.e. with more load), then CSR disclosure practice will need to be regulated since more users are positive on the need to regulate the practice.Where their perception is to the contrary, then Figure 2 will apply.

Research design
Survey research design was adopted in conducting the research.These design method provided primary data on the behavioural perception of users of financial information on the CSR disclosure practices of non-financial sector entities in Nigeria.Questionnaire was administered to a random sample of auditors, accountants and other accounting information users.The population of the study consisted of 400 users of financial statements who reported their behavioural perception on the need to regulate the 128 nonfinancial sector companies listed on the main board of the Nigerian Stock Exchange.In other to achieve this, four hundred copies of the questionnaire were administered to a random sample of the users considered for the study.
was done to ensure that robust, reliable and quality analysis is carried out.A questionnaire was administered to company auditors, accountants and other users of accounting information (regulators, stockbrokers, financial analysts and educators) within Lagos State so as to obtain the perception of these categories of people on the need to regulate CSR disclosure practice of non-financial companies in Nigeria.Though this medium of gathering data is expensive and prone to suffer bias from respondents, its ability to provide data required for generating an optimal solution to the research questions outweighs the perceived disadvantages associated with using it (Adeyemi, 2006).
The research instrument is a 5 point likert scale questionnaire aimed at eliciting different respondents' perception on CSR disclosure practices of non-financial sector organizations in Nigeria.A large number of respondents selected were based in Lagos.The research instrument was tested for validity and reliability.
Content validity was carried out to ensure that the items in the questionnaire measure the attributes in this research.An initial draft questionnaire was distributed to 50 of the sampled respondents.The draft questionnaire was subject to scrutiny and criticism so as to ensure that the interpretations of the instructions and variables under consideration were in accordance with the intended meanings.The comments, additions and corrections were helpful in the preparation of a second (and final draft) questionnaire which was used for the study.
In order to ensure that the consistency of scores obtainable through the instrument is maximized, it was pilot tested.Twenty Five (25) copies of the final draft of the questionnaire were administered to users of financial statements in Lagos.These users included five investors, nine regulators, three academic (Scholars and Researchers), four management and four Information Intermediaries.The result of the Cronbach's Alpha test used to test the internal consistency between variables was remarkable.The Cronbach's Alpha (α) was .851.Out of the 25 questionnaires tested, 100% were recorded as valid cases while none was excluded by the system.Guttman Split-Half was .814while Spearman-Brown equal length test was .814Lambda 1 (.791), Lambda 2 (.892), Lambda 3 (.851),Lambda 4 (.814), Lambda 5 (.877), Lambda 6 (.997) values all revealed appreciable level of reliability.The questionnaire is therefore considered reliable based on this result.The study also ensured that responses came from knowledgeable respondents who possess educational qualification of at least, first degree or equivalent.On the average, the questionnaire took a respondent approximately four (4) minutes to complete.
Descriptive and inferential statistics were used to analyze the data collected.Analysis of Variance (ANOVA) was used to test the two hypotheses.Graphs and frequency distribution tables were also used to enhance the presentation.
All statistical analysis were done using SPSS 17.0

DATA ANALYSIS AND PRESENTATION OF RESULTS
The distribution of the sample according to gender shows that 252 (70%) of the respondents are males while the remaining 102 (30%) are females.This result simply indicates that more male respondents participated in the survey compared to their female counterparts.Qualifications attained by respondents indicates that 10% of them are HND holders, 46.1% of them have a minimum of a first degree from the university, 43.3% have at least a masters' degree while the remaining 0.6% have a minimum of a doctorate degree.In terms of the professional affiliations attributable to each of the respondents, it was observed that 59.2% of them are certified accountants, 5.3% are professional bankers while 6.4% of them are certified stockbrokers.Out of the 359 respondents, 5.6% have insurance affiliations, 4.4% are professional lawyers, and 6.4% are professional engineers while 12.5% said they have affiliations with other professional bodies not listed in the questionnaire, though the remaining 0.3% of the sample did not answer the question.
In relation to the working experience of the respondents, 54.7% which constitutes the majority had between 1 to 5 years of working experience, 18.1% said their years of experience falls within the range of 6 -10 years.The working experience of 14.2% of the sample ranges within 11 -15 years while 5.8% have 16 to 20 years' experience.The remaining 7.2% have more than 20 years of working experience.
It was of interest in the course of the study to determine the group of information user that the respondents belong to.Out of the 360 respondents, 14.4% of them are investors, 30.8% said they belong to the group of regulators while 13.3% belong to the management group.Academics constitute about 35% while the remaining 6.4% are information intermediaries (that is, other users of financial information other than those previously mentioned).
From the survey, it was discovered that 56.9% of the respondents have investment(s) in a public limited company in Nigeria while the remaining 43.1% opined that they have no shares in any of such Nigerian organizations.
Finally based on the table, out of the 205 (56.9%) respondents that declared that they have shareholdings with at least a public limited liability company in Nigeria, 40% of the shareholders have 1 -10 years' experience as investors, 8.6% said they have been shareholders for about 11 to 20 years while the remaining 8.1% stated that they have been shareholders for more than 20 years.In an attempt to answer research question one, a survey was conducted.The researcher attempted to reconcile the perceptions of the users of financial information with the results on the basis of disclosure methodology.Previous researches in this area rarely reconciled theory with practice.It is one thing for statistical analysis on CSR disclosure to reflect a particular result.It is quite another for the targeted users of accounting information to have a contrary perception on the level of CSR disclosure.It thus, became desirable to appraise the level of improvement in CSR disclosure practices from the perspective of the economic stakeholders or decision makers and analysts also.Hypothesis one was used to gain an inference from the perceptions of respondents.

There is no Significant Difference in the User of Accounting Information's Perception of the Level of Voluntary CSR Disclosure in Nigeria
The opinions of the various stakeholders were taken.The results are presented in Table 1.
The perception of the users of accounting information was on a scale of 5, ranging from strongly agreed to strongly disagree.Hence the average score of 2.83 (approximately 3) by the 52 investors shows that they have indifferent opinion on the level of disclosure.The 111 regulators, 48 management respondents and 23 information intermediaries have average score of 2.37, 2.11 and 1.68 respectively which approximates to 2. This implies that these three groups agree with the fact that the level of CSR disclosures by the companies in the non-financial sector have improved over the years despite the fact that it is a voluntary practice.While on the other hand the average of 3.5635 (approximately 4) by the 126 Academics indicates that these group disagree on the level of CSR disclosure made by nonfinancial sector companies in Nigeria.In essence, about 35% of entire respondents disagree with the assertion that CSR disclosure has improved over the years; 51% believed that it has improve; while the remaining 14% of the total sample had an indifferent opinion with respect to the level of CSR disclosure practice of these companies.In order therefore to determine if the observed difference in perception was significant, the Analysis of variance (ANOVA) test was carried out.The result is shown in Table 2.
According to the decision rule in statistics, when the pvalue of the analysis is less than the level of significance (0.05) at which the test was carried out, the alternative hypothesis is accepted.When the p-value is higher than the level of significance at which the test was carried out, the null hypothesis is retained.In this case, the p-value (0.000) is lower than the level of significance (0.05), hence the decision to accept the alternative hypothesis.
This invariably means that there is significant difference in the user of accounting information's perception of the level of voluntary CSR disclosure in Nigeria.
Since the ANOVA test had indicated that there is a significant difference in the perception of users of accounting information on the level of voluntary CSR disclosure.The post-hoc test (Table 3) investigates which of the groups differ significantly.Based on the p-value (Sig.) of pairwise comparison, it is observed that all the values are less than 0.05.This means that comparing any group with the other, there is none that have the sample perception totally.

Research Question 2: THE EXTENT TO WHICH REGULATION CAN IMPROVE CSR DISCLOSURE PRACTICES OF NON-FINANCIAL SECTOR ORGANIZATIONS IN NIGERIA
The objective of this research question was the extent to which CSR disclosure practices of non financial sector entities can be improved through regulation rather than it being a voluntary activity.In an attempt to answer this question, the perception of users of accounting information on the need to regulate the practice was considered.This is the reason for the assertion stated in hypothesis two.
Hypothesis 2: There is no Significant Difference in the User of Accounting Information' Perception of the Need to Regulate CSR Disclosure Practices in Nigeria.The opinion of the various stakeholders was taken and the descriptive statistics carried out (Table 4).At the end of the analysis, it was observed that the average score for the 52 investors, 111 regulators, 48 management and 23 information intermediaries was 2.29, 2.44, 2.54 and 2.04 respectively which is rounded up to 2. This is an indication that a total of 234 (about 65%) constituting more than half of the respondents all agree  with the statements that solicits for the need to regulate CSR disclosure practice.The remaining 126 academics (about 35% of total responses) have an average score of 2.91 (approximately 3).This implies that this group is basically indifferent to the need to regulate the practice.
In order to ascertain whether or not the observed difference in perception was significant, the Analysis of variance (ANOVA) test was carried out.The result is shown in Table 5.
In this case, the p-value (0.000) is lower than the level of significance (0.05), hence the decision to accept the alternative hypothesis.This invariably means that there is significant difference in the user of accounting information's perception of the need to regulate CSR disclosure practices in Nigeria.
Post hoc analysis (Table 6) is carried out to show the pair wise comparison between the groups of users.It can be seen that the p-value for comparison between the group of regulators and management was 0.134 which is higher than the level of significance at which the test was carried out indicating that there is no significant difference in their perception on the need to regulate CSR disclosure.In other words, both the regulators and the management group agree on the need to regulate CSR disclosure practice.This could be attributed to the fact that both groups do basically the same thing though at different level.The management of the company has a role to play in regulating the practice internally (within the organization) while the regulators will be expected to do same externally at the sectoral level.The remaining groups however differ significantly with p-value of less than 0.05 indicating that whatever informs their opinion varies significantly between them.

Research Question 3: HOW THE LEVEL OF CSR DISCLOSURE PRACTICES OF NON-FINANCIAL SECTOR ORGANIZATIONS IN
NIGERIA CAN BE IMPROVED.Adeyemi (2006) suggested that answers to research questions of this sort can be provided for from two major perspectives to the study of accounting: positive perspective and the normative perspective.The positive perspective to the study of accounting theory deals with objectives and is based on facts.It is best known for explaining past financial information.It seems to focus on analyzing the economic statistics and data at hand and deriving conclusions based on those figures.Hence, research questions one and two have relied mainly on the positive approach to the study of accounting, focusing on the data from both primary and secondary sources to make statistical/scientific inferences on the level of CSR disclosure of non-financial sector entities in Nigeria.On the other hand, the normative theory is subjective and tries to describe 'what should be' rather than 'what is'.In essence normative approach unlike the positive approach is more subjective and deals with future events.In essence therefore, the normative approach was adopted in providing answers to research question three, since the aim of the question was to provide suggested answers to better ways of improving CSR disclosure level of non-financial sector entities in the future; taking into due consideration the perceived opinions of several users of financial information, investment experts, academics and economic analysts.
A major contribution from these groups of users suggested that a regulated CSR disclosure system will be a great step towards improving the practice especially for non-financial sector entities in Nigeria.In an attempt to review the Companies and Allied Matters Act of 1990, CSR disclosure could be considered as an important subject that should be incorporated into the Act.The Act should specify punishments for non-compliant firms.This is because it is time CSR disclosure has to be given serious priority just like any other accounting information report.Every non-financial sector entity should be mandated to submit reports of the impact of their activities in Nigeria.The result of this practice will enhance corporate transparency and public confidence in non-financial sector entities in Nigeria (most especially the listed ones).Another approach to improving CSR disclosure practices might be for the government to establish an independent body other than the Corporate Affairs Commission (CAC), which will regularly review and monitor the extent of CSR information disclosed by each company and enforce compliance in line with an applicable working CSR framework.The body should be set up by an Act of parliament with full powers to sanction and punish non-compliant companies.
In addition to a review of the level of CSR disclosure practices of organizations, a platform to reward companies that comply effectively with the established requirements could be established.This will serve as an incentive towards increased disclosure practice.
An independent, private-sector body or committee should also be created with the objective of issuing CSR policy guidelines and frameworks.This can be done in consultation with Financial Reporting Council of Nigeria (FRCN),professional accounting firms such as Klynveld Peat Marwick Goerdeler (KPMG), Price Water House Coopers (PwC), Ernest and Young (EY), and others, engineers, environmental scientists, geoscientists, medical practitioners, energy economists and other professionals whose contributions will see to enhancing CSR disclosure level of companies, especially nonfinancial entities in Nigeria.Many companies might be spending a lot of money on sustainability, renewable energy, reducing Green House Gas emissions, and all other forms of CSR, but the quality of disclosures needs to be improved.This is why a CSR disclosure guideline will be very useful as a guide towards a universal, uniform and transparent manner of presenting CSR information to the public.A CSR disclosure framework issued by the private sector body or committee will also be very useful as a guide towards development of future CSR guidelines or standards.
Incorporating CSR disclosures in the Act, establishing a solid CSR framework and an independent body to review and monitor the practice and enforce compliance will force adamant companies to disclose every information' required to be disclosed.

Summary of the study
There has been an increasing awareness and research into the area of corporate social responsibility reporting over the years.In addition to existing literature in the area of sustainability reporting, this research tried to consider the best alternative to enhancing CSR disclosure practices of non-financial sector organizations in Nigeria.Though most of the existing literature in developing countries including Nigeria assessed the relationships among specific firm variables such as company size, profitability, leverage and CSR disclosure, this study in addition to existing literatures has considered the need to regulate the practice.Survey design was adopted.Four hundred (400) copies of a questionnaire were administered out of which only three hundred and sixty (360) valid responses were received.The study tested the users of accounting information's perception of the level of CSR disclosure practices in Nigeria and the need to regulate the practice.Results from the survey indicate that though 51% of users believe CSR disclosures have improved over the years, there is still a significant difference in their perception.In essence, the users are of the opinion that though the practice has improved, they still have reservations with respect to the level of improvement achieved.Many suggest that a regulation of the practice will provide the needed improvement in the practice.Complimentarily a test of Hypothesis two, indicate that there is no significant difference in the perception of the users on the need to regulate CSR disclosure practice.
Findings from the study reveal that about 65% of the respondents believed that CSR disclosure practices should be regulated in Nigeria.This therefore makes the load (as contained in our model 2; Figure 2) to drive down to the left of our lever system indicating more positive perception on the need to regulate CSR disclosure practices.Out of the 65% that requested that the practice be regulated, the same class of users that perceived that CSR disclosure practices have improved (i.e.management, regulators and financial intermediaries) also believes that a regulation of the practice will bring about the desired level of achievement in CSR disclosure; for example, in terms of an improvement in corporate accountability, disclosure, transparency, and corporate responsibility.Also In their opinion, government (especially government established regulatory bodies), the management of the companies and the private sector still has a role to play in improving the practice and ensuring adequate disclosure and transparency.Result from the pairwise comparison in hypothesis two indicates that there is no significant difference in the perception of regulators and management on the need to regulate CSR disclosure.The non-variation in the perceptions of regulators and management could be traced to the fact that both groups have similar roles to play with respect to CSR disclosure practices, though at different level.While the management is responsible for regulating the practice from within the organization (i.e.internally); the regulator oversees the regulation of the practice externally (at the sectoral level).
Undoubtedly, several studies have been conducted so far (and still on-going) on voluntary CSR disclosure as well as an examination of the need for a CSR disclosure regulation.Outcomes of these studies have produced different results.Constantina (2003) observed that companies under government regulations tend to exhibit ethical business behaviour and act in a socially responsible manner than others and as such regulation should be encouraged.
Frynas (2012) also agreed with the need to encourage CSR disclosure regulation.According to him, "voluntary environmental reporting raises questions about the reliability of self-reported company data."From the Nigerian context, Ihugba (2012) observed that CSR as a voluntary practice is no longer attainable particularly in the petroleum industry.As such his study suggested the need to introduce compulsory regulation into corporate governance via the Nigerian Extractive Industry Transparency Initiative (NEITI) Act 2007.
Contrary to findings from previous researches that looked into the need to regulate CSR disclosure practices Constantina (2003), Frynas (2012), Ihugba (2012) and Reinhardt et al. (2008) however criticized the need for a CSR regulation in developing countries.Their study indicated that the regulation of CSR is a form of legalizing 'profit-sacrificing behavior'.Their argument is that there is no point regulating CSR when regulations can often go unenforced owing to weak legal institutions (e.g. a corrupt judiciary).
The focus of this research has been on how users of financial information feel about the current trends in reporting CSR among non-financial sector organizations in Nigeria, the reliability of information communicated, how regulation of the practice will bring about improved corporate accountability and disclosure among these entities in Nigeria as opposed to previous researches that have ignored key stakeholders perception on the need to regulate the practice (Amao 2008;Achua, 2008)'.Results of responses of respondents have indicated increased disclosure of CSR information.Though majority are still of the opinion that a well regulated practice will reduce the haphazardness in the preparation of such reports, findings from observed responses have revealed that a well-structured framework is important in curtailing the menace associated with voluntary CSR disclosure practice.These findings are however consistent with the studies of Amao (2008), Achua (2008) and Scholtens (2009) It is obvious that most of the entities in question especially the foreign companies take advantage of the weak regulatory system to manipulate their accounts to their favour and provide less detailed information about how they are promoting sustainability activities.Donations, scholarships and employees safety (mostly in the case of manufacturing firms) have been often misconstrued for Corporate Social Responsibility.The argument of this study is that why should the society be at the mercy of these companies?Must we always be subject only to the information they show us in their CSR reports which are grossly inadequate compared to their foreign counterparts or what they publish internationally (for foreign multinationals with group head office outside Nigeria).Since voluntary CSR has failed us in Nigeria, the study has resorted to consider sampling accounting information user's opinion on alternative to voluntary system, which is the regulated system of CSR disclosure practice.This we hope will serve as a better alternative and promote the clamour for a more accountable and transparent practice of accounting information disclosure.
Another point of argument of this study is that in the world today, the issue of corporate responsibility is becoming a human rights issue.Especially when critically analyzed in the context of the effect of business activities on climate change.As Worlds are transferred from generation to generation (literarily, we inherited the one we are in from our fore fathers), it is important for businesses not only to be aware but to act fast on the effect of their activities on future generations and businesses.We must therefore ensure that there is a future to do business and a better world for our children and children's children to live in better than ours which could be guaranteed by an effective and efficiently regulated CSR disclosure practice.

CONCLUSION AND RECOMMENDATIONS
The study which is in three parts has examined how disclosure of CSR information by non-financial sector entities can be improved in Nigeria.A regulated perspective was considered as opposed to the voluntary system currently in practice in the country.The first aspect of the study examined how accounting information users perceive the adequacy and reliability of CSR information disclosure on the basis of the voluntary system currently in practice.Though just a little above average respondents believe that CSR disclosure has increased overtime, it is obvious that CSR information disclosure is still inadequate.Information contained are identified not to be reliable enough by way of responses of the respondents which pose a signaling effect to regulators of the need to take this very seriously; especially in a time like this when there are agitations for increased transparency, accountability and improvements to disclosure of financial and non-financial corporate information.
The second part of the study has been able to establish from users' responses the extent to which regulation can promote CSR disclosure practice.More than 60% of these users have expressed the need for a regulation; most especially regulators and the management.The last study analysis sampled user responses on the best way to go about the challenges associated with the weak disclosure of CSR information of these non-financial sector entities in Nigeria.Suggestive conclusions were made based on previous researches and existing theories in accounting (specifically, the normative and positive accounting theories).The positive accounting theory is more objective in nature and based on facts.However the normative theory is based on 'what should be' rather than 'what is'.It is more subjective in nature.Though the study adopted the positivist accounting approach, having concluded based on opinions of respondents on the need to regulate CSR disclosure practice in Nigeria, the 'what should be' approach to accounting will also support this argument on the basis that it will always be appropriate and right to have a standard CSR disclosure framework for these categories of organizations.In essence therefore, a voluntary system of CSR disclosure cannot even work when there is no standard disclosure framework to guide preparers on items to disclose, how to disclose it, implications of non-disclosure to the company, society and users of accounting information.
In line with the suggestions of Constantina (2003), Frynas (2012), Ihugba (2012), Amao (2008) and Achua (2008) the following recommendations are herewith provided which are intended to provide useful suggestions on better ways to achieving a well regulated CSR disclosure practice in Nigeria: Based on empirical findings on user perception of voluntary CSR disclosure practice in Nigeria, the need for a regulation of CSR disclosure practice is eminent.It appears that without some form of regulatory intervention; reliance on voluntary disclosure alone is unlikely to result in a high quality and or sufficient level of CSR disclosure.This research therefore advocates for a more proactive effort from relevant regulatory bodies and agencies to intervene in ensuring increased disclosure which will complement the International Financial Reporting Standards (IFRS) efforts to enhance corporate accounting information transparency and accountability.An introduction of a standard regulatory framework for the mandatory disclosure of corporate social information should go a long way in improving the practice.
Contributions of Financial Reporting Council of Nigeria (FRCN),the big accounting firms such as Klynveld Peat Marwick Goerdeler (KPMG), PriceWaterHouseCoopers (PwC), Ernest and Young (EY) and others, environmental scientists, geoscientists, medical practitioners, energy experts and other professionals, will go a long way towards achieving a standard regulatory CSR disclosure framework.A major step like this will discourage haphazard disclosure of CSR information and encourage uniformity in CSR disclosure practices which is consistent with the recommendations.
The mechanism for monitoring and enforcing requirements on accounting and financial reporting is provided for in Companies and Allied Matters Act (CAMA) 1990 (as amended), and other acts related to the powers and responsibilities of regulators.The CAMA 1990 (as amended) is termed to be outdated; other shortcomings have also been identified by the World Bank (2011).Although there are current steps to update the contents especially considering developments with respect to IFRS, this study therefore suggests that the need for regulating CSR disclosure practice be incorporated as part of deliberations made in improving the CAMA rules.In addition, the SEC's Investment and Securities Act of year 2007should be revisited, incorporating the mandatory disclosure of CSR information by listed firms and penalties for failure to disclose such information.
An approach to monitoring the regulation of CSR disclosure practices in Nigeria might be for the government to establish an independent body other than the Corporate Affairs Commission (CAC), which will regularly review and monitor the extent of CSR information disclosed by each company and enforce compliance in line with an applicable working CSR framework.The body should be set up by an Act of parliament with full powers to sanction and punish non-compliant companies.
In addition to a review of the level of CSR disclosure practices of organizations, a platform to reward companies that comply effectively with the established requirements could be established.This will serve as an incentive towards increased disclosure practice.

Limitations and areas of further study
The results and conclusions of research such as this should be considered in conjunction with the limitations that are peculiar to research in developing economies.Some of the limitations as identified by Adeyemi (2006) include paucity of accurate data, reticence of respondents and volatile personal characteristics of subjects.In addition to these identified constraints, an extensive study into the behavioural perception of financial information users on the subject under consideration has been limited in so many ways: Firstly, though the study has been limited to respondents in Lagos State owing to the fact that the state is the business hub of Nigeria and home to most professionals, business experts and analysts; it is however important to look beyond Lagos State and consider the perception of other experts outside Lagos.The study has also been limited only to listed nonfinancial sector entities in Nigeria, having taken into consideration the impact of the activities of such enterprises on the society, local communities and the ecosystem.
In view of the limitations of this research, future research in this area of study could be improved on by increasing number of respondents from 400 used in this study to a much higher figure including not just respondents within Lagos only but other states in Nigeria, hence reducing the subjectivity of the current study.Also though non-financial sector entities constitute more than 50% of companies on the Nigerian stock market, the research will be more robust if further studies take to cognizance other non-financial sector entities other than listed ones.
In view of contemporary CSR disclosure challenges, further studies could consider emerging issues like exploring how CSR promotional efforts and regulations may influence the attitudes and perceptions of managers.Another area to explore is how CSR standards are created through public international soft law instruments as identified by Amao (2014), with particular application to the Nigerian situation.

Figure 1 .
Figure 1.A positive User Perception on the Need to Regulate CSR Disclosure Practice.Source: Developed by the researcher, 2013.

Figure 2 .
Figure 2. A negative user perception on the need to regulate CSR disclosure practice.Source: Developed by the researcher, 2013.
and Exchange Commission is the apex regulatory institution of the Nigerian capital market.Financial reporting and disclosure requirements for listed companies are specified in the Investment and Securities Act, 2007 which established the SEC and gave it powers to regulate the Nigerian capital market.Listed companies submit audited annual accounts and report half-yearly financial performance, interim/quarterly financial statements, quarterly earnings forecast, and half-yearly returns on unclaimed dividend warrants to the Securities and Exchange Commission.Though the Securities and Exchange Commission in 2007 established the Financial Standards and Corporate Governance Department to review financial statements of all the publicly traded companies to ensure compliance with the accounting standards and disclosure requirements it appears the initiative remains at the nascent stage (World Bank,

Table 1 .
Descriptive statistics on perception of users on the level of CSR disclosure.

Table 2 .
ANOVA test for difference in perception of users of accounting information.

Table 3 .
Results of post-hoc test on perception of users on the level of CSR disclosure.
The mean difference is significant at the .05level.Source: SPSS Output.

Table 4 .
Descriptive statistics for need to regulate disclosure of CSR activities.

Table 5 .
ANOVA analysis for difference in user perception on the need to regulated CSR disclosure.

Table 6 .
Results of post-hoc test on perception of users on the need to regulate the practice.