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Comparative Corporate Governance: the UK, China and Germany

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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