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Introduction The subject of directors’ duties has formed the topic arguments for many years. Recent considerations for reforming were covered by the Law Commission between the years of 1995 and 1997 with a report being published in 1999. 1 The matter also formed the subject of the Company Law Review (CLR) between 1998 and 2001, which later led to the enactment of the Companies Act 2006 (CA 2006). Prior to the enactment of the CA 2006, the Company Law Review Steering Group (CLRSG) showed their concerns towards to the lack of codified directors duties to be found in the statutes or legal guidelines and the problems this created: these problems being that directors did not know of their exact duties and were also unaware of exactly which and who of the many stakeholders within a company family they owed a duty to. 2 One of the primary objectives of the reform participants of the then upcoming CA 2006 was to rectify this situation and ensure that clarity with regards to directors’ d

The UK, China, and Germany, despite the economic recession, remain corporate giants that stand tall on a history of corporate success. However, mapping their success and the legal framework behind it is far from a case of one copying the other. As Otto-Kahn Freund has forcefully argued, the cultural, economic, and societal characteristics of different jurisdictions are unique and, as such, one should be careful of carbon-copying the laws that work well in one jurisdiction to a wholly different jurisdiction. 1 With this point in mind, it becomes easier to see the reason why different jurisdictions adopt wholly different corporate governance structures and frameworks in the pursuit of a similar goal. The aim of this essay is to examine the corporate governance structures of the three economic Goliaths mentioned above: the UK, China, and Germany. In doing so, this essay will begin by examining the different models of corporate governance that have been adopted by these jurisdictions and l