Comparative legal perspectives on international models of corporate governance

摘要

The present paper aims to provide an interpretation of leading corporate governance paradigms, through several case studies involving four developed economies (that is, the US, the UK, Canada and France) that have implemented either principle-based or rule-based corporate governance systems. A supplementary case study involving Romania, an emerging country, seeks to provide valuable insight into the inconsistencies of applying such a refined corporate governance system to an emerging market. From a methodological standpoint, preeminence is given to a comparative and critical approach. Finally, we ask the following question: which are the most appropriate ways to insure the crystallization of legal aspects concerning corporate governance, in the context of international diversity and, sometimes, divergence?