Corporate governance has become a bonafide subset of company’s law that is concerned with who directs the company and for whose benefit. Its application varies in countries found in the main legal jurisdictions of common and civil law. This thesis identifies these differences by highlighting national corporate governance systems existing in Germany, Japan, United Kingdom and United States. Together, these countries represent systems adopted by several countries located on all continents. Increased cross border investment in this era of globalization has been significantly affected by these governance systems. The thesis shows the reasons why investors, multinational corporations and nations have put corporate governance on their agenda’s. The thesis also discusses the theory of convergence, which predicts that competition will eventually cause the various national governance systems to converge into a single model. Finally, the attempt to create this single model by the Organization of Economic Cooperation and Development is explored.

Included in

European Law Commons