Corporate Governance in India: The Case of HDFC Bank

Kirti Ranjan Swain*

This paper reviews the existing codes of Corporate Governance (CG) in India. It analyzes the CG structures and practices in HDFC bank by using a case study methodology. It uses both primary and secondary data for analyzing the adaptability of CG codes in the Indian context. The primary data regarding the extent of CG practices and reporting in HDFC bank were collected from various towns of Orissa and the secondary data were collected through various published and unpublished reports and websites. The paper reveals that India has a good CG mechanism and disclosure practices on par with world counterparts.

Introduction
In India, Corporate Governance (CG) has assumed importance mainly in the wake of economic liberalization, and deregulation of industry and business. An unbridled pursuit of profit paves the way for unmitigated disaster. Hence, as a guiding principle, it has been prescribed in the Upanishads to enjoy with restraint and renunciation. While planning for tomorrow and grooming the future trade leaders, spiritualism and values need to be inculcated in them. The manipulations and financial fraud done by Ramalingam Raju, proved disastrous for the software giant Satyam, the investors, employees, stakeholders and above all the goodwill of the nation. Price Water Coopers, the audit firm was also involved in this fly-by-night deal and produced a doctored balancesheet to suit the dark designs of Raju. So, good CG is a necessity in the present corporate world to build the confidence of the stakeholder, employees, and interested groups of people. This paper primarily focuses on the codes of CG in emerging economies, which is a driving force for corporate performance and overall economic prosperity. Particularly, in case of India, it is most important because India is one of the fast growing economies of the world. The corporate sector in India remains changing and moving ahead as per the developments that are taking place in other counterparts and developed economies like the US, the UK and other parts of the corporate world. The infamous collapse of Enron in 2001, one of the Americas largest and celebrated companies, has turned the international attention on corporate frauds and the role that a strong CG needs to play to prevent the frauds to happen (Solomon, 2007). The US enacted
* Faculty, Alphia Institute of Business Management, Bhubaneswar, India. E-mail: kirtiranjans@yahoo.com 119

Corporate Governance in India: The Case of Reserved. 2009 The Icfai University Press. All Rights HDFC Bank

the Sarbanes Oxley Act (2002) in response, while the UK responded by producing the Higgs Report (2003) and Smith Report (2003). In India, the CG movement gathered momentum after the publication of the report of Confederation of Indian Industry (CII) on desirable code of CG in 1997. The amount of research carried out in CG in the context of India lacks research evidences to make effective comparisons with its counterparts as well as developed economies to strengthen the governance codes and good mechanism. It is imperative to generate research literature on this subject. Therefore, this paper tries to analyze the code of CG and its effectiveness in the context of India by using a case study method. This paper has discussed some research questions like: What is CG? What is the background of CG? What are the drivers of CG? Are CG reforms necessary? What is a good CG? and What is the compliance of best codes of governance? The paper sums up the analysis of CG practices in HDFC banka leading Indian private sector bank in CG practices.

Corporate Governance in the World Scenario

Corporate Governance has become a buzz word in the corporate sector. It has emerged as a means of corporate excellence and driving force for attaining greater performance, maximizing the wealth of the stakeholder and corporate value. Yet, there is a little evidence that good governance can prevent further corporate failure or contribute to improved organizational effectiveness (Moxey, 2004). Several committees and commissions have been appointed to probe into various issues and to make appropriate recommendations for better CG practices. The Russian economy collapsed in 1998. Likewise, the Asian financial crisis also demonstrated that even strong economies lacking transparent control, responsible corporate boards and shareholder rights can collapse due to dilution of investors confidence. Consequently, various countries in the world have adopted the CG reforms (Table 1). Due to the frauds and financial deficiencies involved in the corporate sector in the US and the UK, the CG practices gained more attention.
Table 1: Corporate Governance Across the World Year 1992 1994 1995 1996 1997 1998 1999 United Kingdom South Africa and Canada Australia, France and Pan-Europe Spain USA, Japan and The Netherlands India, Belgium, Germany, Italy, and Thailand Brazil, Greece, Hong Kong, Ireland, Mexico, Portugal, South Korea, OECD, ICGN, Commonwealth (Cont.)
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Country

Table 1: Corporate Governance Across the World Year 2000 2001 2002 2003 2004 2005 2006 2007 Country Denmark, Indonesia, Kenya, Malaysia, Romania and Philippines China, Czech Republic, Malta, Peru, Singapore and Sweden Austria, Cyprus, Hungary, Kenya, Pakistan, Poland, Russia, Solvakia, Switzerland and Taiwan Finland, Lithuania, Macedonia and New Zealand, Turkey, Ukraine and Latin America Argentina, Bangladesh, Iceland, Norway, Slovenia and OECD Jamaica, ICGN, Latvia and Lithuania Estonia, Lebanon, Luxemburg, Nigeria, Sri Lanka and Thailand Bulgaria
Source: Solomon (2007), Corporate Governance and Accountability, p. 188

Corporate Governance in the Context of India

The CG problems in every country are unique and this is because of the path dependence (Bebchuk and Roe, 1999). CG problems in India also have their own uniqueness because of the business models and structures it had in the past. Bhasa (2003) traces and analyzes the history of Indian business models from 19th century to the present day. The term CG became a prominent research theme after the publication of Cadbury Committee report in the UK during the 1990s. This is evident from the fact that the number of research papers published in the peer-reviewed scholarly journals in the area of CG has gone up from 641 during 1985-96 to 9,717 during 1996-2006 (Balgobin, 2008). Unlike many other research areas in business, the CG literature also covers developing countries, particularly those in Asia. In India, the CG movement gathered momentum after the publication of the report of CII in desirable code of CG in 1997. Since 1997, no attempt has been made to survey the literature of CG in India and also to review the literature on CG in the Indian context, Though the focus is on the work done in the Indian context, this paper considers the research work done in rest of the world for comparison. This paper classifies the research work on CG in the Indian context into various categories. The research papers analyze the nature and emergence of CG in India and highlight that though CG in India is moving towards Anglo-American model, the ownership pattern of Indian business is different from that of the Anglo-American environment. The academic research in the field of CG has grown tremendously since Shleifer and Vishny (1997) published their pathbreaking survey of literature on CG. Most of the shortcomings in Indian CG systems are no worse than other Asian countries and its banking sector has one of the lowest proportions of nonperforming assets, signifying that corporate fraud and tunneling are not out of control (Chakraborthi et al., 2008). The governance of most of the industrial and business organizations in India was based on unethical business practices. A scant regard
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has been given to the human and organizational values while dealing with their stakeholders in the organization. The increasing corruption in the government and its various services has kept the management of industrial and business organizations above accountability for their misdeeds, thereby encouraging them to indulge in more unethical practices. The state-owned organizations occupy a dominant position in the countrys economy and being monopolistic, force the consumers to pay the costs of their corporate misgovernance. Organizations in the private sector, barring a few exceptions, indulge in all possible unethical practices to fleece their customers on the one hand and deny the benefits to them on the other. The scandals in a large number of private corporations during the last one decade, clearly indicate the nature and extent of corporate misgovernance that exist in the private sector. Gollakota and Gupta (2006) divided the evolution of corporate governance in India into four phases and identified the value system associated with business enterprises during those periods. They are given below: Phase I: Pre-independence (until 1947)eco-centrism and family ownership.

Phase II: The License Raj (19471-1981)social altruism and public enterprises. Phase III: Knowledge of professionalism (1981-1991)social justice and professional ownership. Phase IV: Liberalization (1991 onwards)eco-centrism and foreign ownership. After briefly analyzing the historical background, we now describe the major changes that happened in the governance and regulatory system in India including the bank governance and the public sector enterprises governance. The Securities and Exchanges Board of India (SEBI), has made a significant progress in providing a rigorous regulatory regime that helps to ensure transparency and fair practice. But there are some areas of concern as well. Despite the fact that the country has a well-functioning banking sector and ranks high in getting credit, a majority of the countrys Small and Medium-Sized Enterprises (SMEs) still rely on relationship-based, informal control and governance mechanisms that limit financing and keep the cost of capital high. It is found that the enforcement mechanism is not very strong and that has resulted in a system where even in large companies, the shareholdings remain relatively concentrated with promoters. There is significant evidence showing the presence of pyramidal structures and tunneling among the Indian business groups despite stringent regulatory requirements. Many researchers (Chakraborthi et al., 2008) argued that the Indian CG environment has been changing since the past decade, particularly with the enactment of the Sarbanes-Oxley-Type Measures in Clause 49 of the listing agreements. The changes are already visible with the rise of successful companies like Infosys, which are completely free from the influence of a dominant family or group, and have made the individual shareholder, its central governance focus.

Driving Forces of Corporate Governance

As indicated previously, the CG scenario in India has been changing fast since the mid-1990s, and it gained pace after the enactment of Sarbanes-Oxley-Type Measures and legal changes
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to improve the enforceability of the creditors rights. India should have the quality of regulatory institutions to sustain its impressive current growth rates in the future (Chakraborthi et al., 2008). For this purpose, one has to first understand a good CG system and its driving forces. A good CG is a reflection of quality management with highest caliber understanding the role, which a good CG plays in maintaining checks and balances within the organization, while increasing transparency and preventing corporate abuse and mismanagement. The CG provides a mechanism, which improves the efficiency, transparency and accountability of the corporates and builds the confidence of the stakeholders. CG systems also describe the structure of rights and responsibilities among the parties that have a stake in the firm (Aguilera and Jackson, 2003). But the kind of responsibility and structure of the firm varies from region to region and country to country including the emerging economies. These economies however, provide unique opportunities and challenges for governance practices and research (Davis, 2005) as little amount of research has taken place in these countries. In this context, an effort is made to identify the driving forces of CG in India. There are certain major driving forces, which have resulted in the emergence of CG in India and these include: (1) globalization; (2) unethical business practices and security scams; (3) privatization; (4) ownership/capital structure; (5) institutional investors; (6) board characteristics and firm performance; (7) executive compensation; and (8) nature and emergence of CG system in India. After a detailed analysis, it is concluded that in Indian system, certain driving forces take more important role for better CG practices required for the effective and efficient management of the corporate sectors. Otherwise it goes like Satyam. This paper now discusses the CG system in HDFC bank Ltd., one of Indias leading private banks, which is known for its sound CG practices.

Corporate Governance Practice: A Brief Analysis of HDFC Bank Ltd.

Philosophy on the code of Corporate Governance
HDFC bank has explicitly defined the code of CG in Table 2. Its website states, the bank believes in adopting and adhering to the best CG practices and continuously benchmarking itself against each such practice. The bank has infused the philosophy of CG into all its activities. The philosophy on CG is an important tool for shareholder protection and maximization of their long-term values.

Board of Directors
The annual report for the period 2006-2007 of HDFC bank highlights that the composition of the Board of Directors of the bank is governed by the Companies Act, 1956, the Banking Regulation Act, 1949 and the Clause 49 listing requirements of the Indian Stock Exchanges, where the securities issued by the bank are listed. The HDFC Board has nine Directors as on March 31, 2007. All the Directors, other than Aditya Puri, are non-executive directors. The bank
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Table 2: Corporate Governance in HDFC Bank

Basis of Comparison HDFC Bank Brief Statement on Banks Philosophy on Code of Governance Philosophy on Code of Governance Proper disclosure Board of Directors Nature of Board Composition of the Board of Directors Independent Directors and the Definition of Independence Nominee Directors Chairman of the Board Attendance of Each Director at the BOD Meeting Number of BOD Meetings Held and Dates Proper disclosure; Chairman is non-executive and part time Proper disclosure Eight out of nine are non-executive directors, four independent and five non-independent directors; definition of independent directors is not disclosed Disclosure is not very clear, information is provided partly Shri Jagdish Capoor Proper disclosure Eight Board Meetings were held on April 17, 2006; May 30, 2006; July 14, 2006; August 29, 2006; October 17, 2006; December 5, 2006; January 11, 2007; and March 29, 2007 Audit Committee Composition and Name of the Chairperson Meetings and Attendance During the Year Independence Frequency of Meetings and Forums Powers of the Audit Committee Functions of the Audit Committee Proper disclosure, Shri Ranjan Kapoor, Chairman of the committee No proper disclosure regarding the dates of the meetings held; Six meetings held Proper disclosure; All are independent and non-executive Directors Proper disclosure; Two months Proper disclosure Proper disclosure Remuneration Committee of the Board Attendance During the Year Remuneration Policy Composition, Quorum of the Remuneration Committee
124

One meeting held, Shri Jagdish Capoor is the chairman of the committee Proper disclosure and transparent policy No proper disclosure (Cont.)
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Table 2: Corporate Governance in HDFC Bank

Basis of Comparison Disclosure of Remuneration Package Board Meeting (Atleast Four) Restriction of Chairmanship (Five companies) Restriction from Membership (10 Companies) HDFC Bank Proper disclosure and transparent policy Board Procedures Proper disclosure: All attended a minimum of four meetings except Amla Samant and Vineet Jain Proper disclosure: None of the directors is the chairman of more than five committees Proper disclosure: None of the directors is the member of more than 10 committees Shareholder Committee Name of Non-executive Director Heading the Committee Name and Designation of the Compliance Officer Proper disclosure: Shri Jagdish Capoor is the chairman of the committee Proper disclosure: Shri Sanjay Dongra, VP (Legal), Company Secretary

Number of Shareholders Proper disclosure: 193 Complaint Received in a Year Number of Complaints Unsolved Number of Share Transfers Pending Proper disclosure: Nil Proper disclosure: 136 General Body Meetings Location and Time of Last Three AGMs Were Special Resolutions Passed? Details of Voting Patterns (Physical and Postal Ballot) Person who Conducted Postal Ballot Exercize Procedure for Postal Ballot Proper disclosure Proper disclosure Proper disclosure: Only physical voting, so no need of postal ballot system. Proper disclosure: Not applicable Proper disclosure: Not applicable Disclosures Disclosure on Materially Significant Related Party Transaction Proper disclosure: There are no materially significant related party transactions which have potential conflict with the interest of the company at large (Cont.)
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Table 2: Corporate Governance in HDFC Bank

Basis of Comparison Details of Non-compliance and Penalties Imposed on the Company by SEBI HDFC Bank Proper disclosure: All requirements of stock exchanges and SEBI and other statutory authorities are duly complied. No penalties or strictures have been imposed by the stock exchanges and SEBI General Shareholder Information AGM Date, Time and Venue June 17, 2005 (11th AGM), the time and venue is not disclosed Financial Calendar Date of Book Closure Dividend Payment Date Listing of Stock Exchanges Stock Code Proper disclosure: Year ending March 31 Proper disclosure: May 28, 2005 to June 17, 2005 (both days inclusive) Proper disclosure: June 18, 2005 Proper disclosure: The BSE, Mumbai, The NSE, Mumbai Proper disclosure; The BSE, Mumbai 500180 The NSE, and Mumbai-HDFC Bank

Market Price Data, i.e., Proper disclosure: Data of high, low, average volume per day, High/Low During Each Month average number of trades per day and value per day for the period in Last Financial Year from April 2006 to March 2007 Performance through BSE, SENSEX, CRISII, Index, etc. Registrar and Transfer Agents Proper disclosure Proper disclosure: Mrs. V Sajan/Mr. S Manve/Mr. V Deshmukh, MCS Inf. Registrars and Transfer Agents, Unit: HDFC Bank, Shree Venkatesh Bhawan, Plot No. 27, Road No. 11, MIDC Area, Andheri (E), Mumbai 400093, Tel: 022 28215235/6/7; FAX: 022 28350456; E-mail: mcssvp@eth.net Proper disclosure Proper disclosure

Share Transfer System Dematerialization of Shares

Address for Correspondence Proper disclosure: HDFC Bank, 2nd Floor, Process House, Senapati Bapat Marg, Kamla Mills Compound, Lower Parel (W), Mumbai 400013; Tel: 022 24988484, 24961616, Et. 3463, FAX: 022 24965235. E-mail: investorhelpdesk@hdfcbank.com

has four independent directors and five non-independent directors. The annual report points out that the Board consists of eminent persons with considerable professional expertise and experience in banking, finance, agriculture, small-scale industries and other related fields.

Corporate Governance System in HDFC Bank

HDFC bank has emphasized the definition of CG given by OECD which is as follows: Corporate governance is the system by which business corporations are directed and controlled. The Corporate governance structure specifies the distribution of rights and responsibilities among different participants in the corporation and spells out the rules and procedures for making decisions on corporate affairs.
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Governance Policy in HDFC Bank HDFC bank has laid the foundation for CG in line with international best practices.
The chairman is a non-executive director. Not more than 25% of the Board comprises of executive members. HDFC bank Board has many board committees including the following: Audit Committee Board Governance Committee Management Committee Majority of Board committees are presided over by independent professional directors. The Board is responsible for policy formulation, setting up of goals, and evaluation of performance and exercising control. The Board sub-committee is responsible for overseeing the functions of the management. There is a complete separation of executive management from the Board functioning.

Findings
An evaluation of the results reveals that HDFC has shown very good performance in the disclosure policies of CG and attaining the quality of governance practices. The areas, which HDFC bank needs to pay attention are: Disclosure of the power and responsibility for designations at at the helm of affairs of the bank, i.e., to the post of chairman and CEO. Disclosure of tenure and age limit of all the executives, non-executives as well as independent directors. Disclosure of the definition of independent director, financial expert, and disclosure of selection criterion for non-executive and independent directors. Proper appointment of Lead Independent Director in the Board in strict compliance with the provisions of Clause 49 I (A) (iii) (a) and (d) (ii) of SEBI Listing Agreement. Disclosure of breakup of remuneration policy as well as detailed breakup of salary, fixed component and performance linked incentives, perks and allowances of each executive director separately. Affirmation of compliance code of conduct and declaration to the shareholders in a proper and acceptable format.
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 Disclosure of the reports of Audit Committee, Remuneration Committee and Shareholders/Investors Grievance Committee in the CG report. Constitution of separate board committees for effective governance of the companys affairs, e.g., Ethics Committee, Nomination Committee, Investment Committee, etc., and disclosure of the reports of these committees in the annual report. Disclosure on mechanism of evaluation of non-executive directors performance in the bank.

Conclusion
The emergence of CG has its own history in different parts of the world. In the present global environment, where economies are integrated with global market environment, it is imperative to develop a sound system of CG. It is more so in emerging economies like India. The first major stimulus for CG reforms was the Southeast Asian crisis during 1997-98 followed by the Enron debacle in 2001, which necessitated the need for ensuring better CG practices, culminating in the enactment of legal measures like Sarbanes-Oxley Act of 2002 in the US. Though there are exceptions like Global Trust Bank and Satyam Computer, India did face miserable corporate failures as in the west, such as Enron, Maxwell, WorldCom, etc. In India, the initial drive for better CG and disclosureperhaps as a result of the 1992 stock market scam and the fast emerging international competition as a consequence of liberalization of the economy that began in 1991came from the CII and the Department of Corporate Affairs. HDFC Bank is one of the largest private sector bank in India, whose practices attract a lot of attention. In spite of some limitations of the study, the primary and secondary sources of data help us to pinpoint the effectiveness of CG practices in HDFC bank. It is important to note the areas where HDFC bank needs to improve its CG practices.

Bibliography
1. Afrait S N (1972), Efficiency Estimation of Production Functions, International Economic Review, Vol. 13, No. 3, pp. 568-598. 2. Aguilera R V and Jackson G (2003), The Cross-National Diversity of Corporate Governance: Dimensions and Determinants, Academy of Management Review, Vol. 28, No. 3, pp. 447-465. 3. Anderson P and Petersen N C (1993), A Procedure for Ranking Efficient Units in Data Envelopment Analysis, Management Science, Vol. 39, No. 10, pp. 1261-1265. 4. Ayadi O F (1998), Bank Performance Measurement in a Developing Economy: An Application of Data Envelopment Analysis, Managerial Finance, Vol. 24, No. 7, pp. 5-16. 5. Balgobin R N S (2008), Global Governance Practice: The Impact of Measures Taken to Restore Trust in Corporate Governance Practice Internationally, The Icfai Journal of Corporate Governance, Vol. 7, No. 1 , pp. 7-21.
128 The Icfai University Journal of Corporate Governance, Vol. VIII, Nos. 3 & 4, 2009

6. Bauer P W, Berger A N and Humphery D B (1993), Efficiency and Productivity Growth in US Banking, in Fried H O Lovell C A K and Schmidt S S (Eds.), The Measurement of Productive Efficiency, pp. 318-413, Oxford University Press, New York. 7. Bauer P W, Berger A N, Ferrier G D and Humphery D B (1998), Consistency Conditions for Regulator Analysis of Financial Institutions: A Comparison of Frontier Efficiency Methods, Journal of Economics and Business, Vol. 50, pp. 85-114. 8. Bebchuk L A and Roe M J (1999), A Theory of Path Dependence in Corporate Ownership and Governance, Stanford Law Review, Vol. 52, No. 1, pp. 127-170. 9. Berg S A, Frsund F R, Hjalmarsson L and Suominen M (1993), Banking Efficiency in the Nordic Countries, Journal of Banking and Finance, Vol. 17, Nos. 2-3, pp. 371-388. 10. Berger A N (1993), Distribution-Free Estimates of Efficiency in the US Banking Industry and Test of the Standard Distributional Assumptions, Journal of Productivity Analysis, Vol. 4, No. 3, pp. 261-292. 11. Bhasa M P (2003), From Property Rights to Shareholder-Stakeholder Debate: A Brief Look Into the Emergence of the Notion of Corporate Governance, The Icfai Journal of Corporate Governance, Vol. 2, No. 2, pp. 88-99. 12. Bhattacharyya A, Lovell C and Sahay P (1997), The Impact of Liberalization on the Productive Efficiency of Indian Commercial Banks, European Journal of Operational Research, Vol. 98, No. 2, pp. 332-345. 13. Chakrabarti R, Megginson W and Yadav P K (2008), Corporate Governance in India, Journal of Applied Corporate Finance, Vol. 20, No. 1, pp. 59-72. 14. Das A (1997a), Technical, Allocative and Scale Efficiency of Public Sector Banks in India, Reserve Bank of India Occasional Papers, Vol. 18, Nos. 2-3, pp. 279-301. 15. Fan I (2004), Efficiency, versus Risk in Large Domestic US Banks, Managerial Finance, Vol. 30, No. 5, pp. 1-19. 16. Gollakota K and Gupta V (2006) History, Ownership Forms and Corporate Governance in India, Journal of Management History, Vol. 12, No. 2, pp. 185-192. 17. Grosskopf S (1996), Statistical Inference and Non-parametric Efficiency: A Selective Survey, The Journal of Productivity Analysis, Vol. 7, No. 2-3, pp. 161-176. 18. Halkos G E and Salamouris D S (2004), Efficiency Measurement of the Greek Commercial Banks with the Use of Financial Ratios: A Data Envelopment Analysis Approach, Management Accounting Research, Vol. 15, No. 2, pp. 201-224. 19. Mohan T Ram and Ray S (2004), Productivity Growth and Efficiency in Indian Banking: A Comparison of Public, Private, and Foreign Banks, Working papers 2004-27, University of Connecticut, Department of Economics.
Corporate Governance in India: The Case of HDFC Bank 129

20. Moxey P (2004), Corporate Governance and Wealth Creation, The Association of Chartered Certified Accountants, ACCA Occasional Research paper No. 37. 21. Shleifer A, and Vishny R (1997), A Survey of Corporate Governance, Journal of Finance, Vol. 52, No. 2, pp. 737-783. 22. Sol on JF ( om 2007) Corporate Governance and Accountability, 2nd Edition, John Wiley Inc. , 23. Weill L (2003), Banking Efficiency in Transition Economies: The Role of Foreign Ownership, Economics of Transition, Vol. 11, No. 3, pp. 569-592. 24. Weill L (2004), Measuring Cost Efficiency in European Banking: A Comparison of Frontier Techniques, Journal of Productivity Analysis, Vol. 21, No. 2, pp. 133-152. 25. Weill L (2007), Is there a Gap in Bank Efficiency Between CEE and Western European Countries?, Comparative Economic Studies, Vol. 49, No. 1, pp. 101-127. 26. Williams J and Nguyen N (2005), Financial Liberalization, Crisis and Restructuring: A Comparative Study of Bank Performance and Bank Governance in South East Asia, Journal of Banking & Finance, Vol. 29, Nos. 8-9, pp. 2119-2154. 27. www.hdfc.com 28. www.hdfcbank.com 29. www.highbeam.com 30. www.rbi.org 31. www.corpgov.net 32. www.worldbank.org.in 33. www.oredaorissa.com 34. www.orissa.net

Reference # 04J-2009-07/10-06-01

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