Exploring Legal Pathways for Sustainable Corporate Governance in the United Kingdom and Germany: A Comparative Analysis of Labour Law and Competition Law

Abstract

This research analyses how UK and German labour legislation, competition law, and non-financial reporting systems affect sustainable corporate governance, focusing on environmental compliance and fair labour practices. The study evaluates legislation, case law, EU directives, and academic literature using a qualitative comparative legal research methodology, which incorporates a PRISMA-based systematic literature review. Results revealed that the UK uses soft-law procedures, which are flexible but unenforceable, whereas Germany uses hard-law tools like codetermination and statutory ESG responsibilities, which improve compliance but restrict regulatory agility. UK competition law is sceptical of sustainability cooperation, whereas Germany is pro-sustainability. Germany emphasises innovation in non-financial reporting, whereas the UK emphasises storytelling. The paper advances cross-jurisdictional governance literature and recommends integrated, enforced, and innovation-friendly ESG governance.