Comparative and International Corporate Governance

Abstract

In this article, we examine the state of the art in comparative and international corporate governance by identifying the key research questions, main concepts, and paradigms of explanations of cross-country diversity in corporate governance. First, we discuss the multiple definitions of corporate governance across disciplines and explore how this multi-dimensional nature of corporate governance posses challenges when making cross-national comparisons. Second, we review existing comparative research on corporate governance and highlight some of the main characteristics of comparative analysis. Third, we analyze how comparative corporate governance has been understood from four different scholarly perspectives: economics and management, culture and sociology, legal, and political paradigms. We conclude from this third section that future research should make an effort to 486 • The Academy of Management Annals better integrate cross-disciplinary paradigms. Fourth, we investigate what insights these four perspectives bring to understand change and stability better in two particular governance dimensions: corporate ownership and the role of labor in comparative corporate governance. Finally, we conclude the article with some forward looking suggestions regarding (1) how different perspectives of corporate governance can be more effectively integrated by adopting case-based, historical, and actor-centered forms of institutional explanations and by (2) discussing the current U.S. corporate governance system, frequently seen as the "best practice" model.

Corporate Governance and Law Enforcement in Albanian Joint Stock Companies

“…Whilst substantial changes have been reported in different countries, it seems to exist two distinct legal groups of CG: common law and civil law. The former is based on jurisprudence and is commonly associated to Anglo-American countries; the latter is based on codes and is commonly associated to Continental Europe (Aguilera and Jackson, 2010). Several authors (e.g.…”

“…There is consensus between all international bodies working on CG that regulations are not uniform across the world, and implementation, domestic circumstances and priorities should be taken into account (Yuksel, 2008;Aguilera and Jackson 2010). Different legal jurisdictions impose a diverse sort of constraints to reduce (or to enhance) the opportunism among the multiple constituencies of the firm (Aguilera and Jackson, 2010). Due to political and economic development, countries have made changes to their corporate legislation over the years (Martynova & Renneboog, 2011).…”

“…Moreover, the premium price paid by institutional investors from around the world is higher in countries with weak legal protection of investors. There is consensus between all international bodies working on CG that regulations are not uniform across the world, and implementation, domestic circumstances and priorities should be taken into account (Yuksel, 2008;Aguilera and Jackson 2010). Different legal jurisdictions impose a diverse sort of constraints to reduce (or to enhance) the opportunism among the multiple constituencies of the firm (Aguilera and Jackson, 2010).…”

“…companies have to comply with the developing standards of the market) (Aguilera & Jackson, 2010), and due to financial crisis there have been attempts to set-up supra-national governance codes. These universal standards represent common important features to "good" CG.…”

A Cross-country Study of the Effects of Institutional Ownership on Credit Ratings

“…The Continental European or stakeholding corporate governance model has several unique characteristics. One of these is the emphasis on maximisation of stakeholder interest, which includes employees and other stakeholders, where investment is carried out on a long term basis as opposed the short term is that characterises investment in the United States and the U.K. (Aguilera & Jackson, 2010). In fact, according to these authors, the stakeholder approach as seen in the case of Germany as well as in Japan is characterised by "patient capital" when compared to the "short-termism" in investment observed in the United States and the U.K. (Aguilera & Jackson, 2010, p. 553).…”