Comparision of Corporate Governance in Different Countries in Report Foemat

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A Comparison of Corporate Governance Systems in Four Countries

Jüergen Schneider Ernst & Young Deutsche Allgemeine Treuhand AG Siu Y. Chan Hong Kong Baptist University

A Comparison of Corporate Governance Systems in Four Countries

Jüergen Schneider Ernst & Young Deutsche Allgemeine Treuhand AG, Heilbronn branch, Germany and Siu Y. Chan* Hong Kong Baptist University, Hong Kong

*

Address of Correspondence: Dr. Siu Y. Chan, Department of Accountancy and Law, Hong Kong Baptist University, Kowloon Tong, Kowloon, Hong Kong.

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A Comparison of Corporate Governance Systems in Four Countries

Abstract Companies in different countries are operating in different cultural, legal, social and economic environments. As a result,
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This understanding is helpful for policy makers to evaluate the advantages and disadvantages of implementing a particular philosophy on their corporation laws and adopting a particular board model. This study starts with a brief review of the prior research on the corporate governance systems in a variety of different countries. It then analyzes the structures of German

supervisory boards (Aufsichtsrat), US boards, Switzerland boards (Verwaltungsrat) and French boards (conseil d’administration and conseil de surveillance). From these analyses, this study attempts to identify the key features of these structures that may make the monitoring functions of the boards more successful.

2. Prior Research Although several studies have examined corporate governance systems, most of them focus on the system of a particular jurisdiction only. Very few compare corporate governance systems across different countries. Among these few, for example, Bleicher, Leberl and Paul (1989) conduct two extensive research projects to compare the legal requirements and the actual practices of the corporate governance systems among listed corporations in Germany, the US and Switzerland. They recommend that some monitoring practices for these

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companies be developed (Bleicher et al., 1989, p. 259).

They conclude that the

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