Civil society’s business case approach has been predicated on the intensive accountability of most businesses, especially publicly listed companies, to shareholders with a predominantly financial interest. In its modern form this approach is associated with the failure of civil society in the 1970s and 1980s to successfully advocate for either renewed economic nationalization or a shift in international corporate governance towards more pluralistic accountability structures. In practice, there have been some gains in this latter respect, with extended trench warfare focused on definitions of materiality, public disclosure, and the rights of minority shareholders that has significantly increased accountability to nonfinancial shareholders in some countries, despite the resilience of the underlying Anglo Saxon model of fiduciary responsibility to financial capital.