Corporate Governance Models and the Possibility of Future Convergence

Abstract

This study explains the main corporate governance models used in the United States of America, United Kingdom, Germany and Japan by analyzing their similarities, differences, strengths and weaknesses. In addition, the possibility of future convergence between these models is discussed. Two types of corporate governance models are used in the world: Shareholder and Stakeholder models. In this study, USA, and UK will be analyzed as an example of the shareholder model, whereas Germany and Japan will be discussed as an example of the stakeholder model. The shareholder model emphasizes the benefits of shareholders and the management dominates the decision-making procedure of the companies. The stakeholder model, on the other hand, puts more emphasis on the interests of stakeholders or capital market players such as the workers, suppliers and the public. On the convergence debate, four different arguments are identified: The first and the main one is against convergence seeing it as a distant dream because of the differences between the countries. The second argument supports and expects convergence in the near future. The third argument supports the argument of functional convergence rather than formal convergence. The fourth argument supports the combination of both shareholder and stakeholder models to get effective corporate governance practices.

This research supports the first argument which is against convergence, because looking at the differences between the countries in their economic, legal and political frameworks, it is still impossible to suggest convergence. Each country will continue to adopt its style according to its culture and also according to its differing needs.