Who is undermining employee involvement in postsocialist supervisory boards? – National, European and international forces in the revision of Hungarian company law

“Good” Corporate Governance in Transformation Countries — A Comparison of Experts' Perceptions in East Germany, Estonia and Hungary

“…The finding that East German respondents explicitly differed in their positions on the role of the state, board information provision, and board remuneration clearly mirrors the controversial public debate about these topics at the time of our interviews (Steger and Hartz, 2005). The same can be said about the (problematic) interplay between managers and owners in Estonia (Tafel and Alas, 2006) or the (questionable) role of the CG code in Hungary (Vliegenthart, 2009;Martin, 2010). The fact that the employee matter was broadly discussed by the East German experts, in sharp contrast with their Estonian and Hungarian colleagues, does not only reflect the employees' strong legal position in the (East-)German CG system but also the strong public interest in this topic (Steger and Hartz, 2005).…”

“…While the influence of the Anglo-American model is more explicit (e.g., company representatives demanding to follow the liberal way (Vliegenthart, 2009)), the German model's impact is rather implicit (e.g., the legal system's structure (Zattoni and Cuomo, 2007)). Moreover, some historically rooted norms and values could be found (e.g., the "honorable merchant" in East Germany, the recognition of the national context in Hungary, social groupings from the socialist times), as well as some postulates reflecting the transformation process (e.g., for legal framework enforcement in Hungary and Estonia).…”

“…With continuous growth rates above European Union (EU) average, Hungary has been attracting a lot of international investors, which, at the same time, made the country highly dependent on foreign multinational companies and led to some fairly ambiguous results. While the Hungarian legal structures often followed German models, Hungarian companies and management, against the background of the powerful multinationals, seem to follow Anglo-American models (Galgóczi, 2003;Vliegenthart, 2009). With respect to CG, Hungary introduced a mandatory supervisory board side by side with an Anglo-American fashioned board of directors (Török, 1998).…”