What connects and what differentiates the corporate governance systems of selected countries?

Abstract

convergence or divergence of corporate governance systems on the basis of selected countries – the US, the UK, Germany, and Japan. The research should show that the governments of these countries are not interested in the convergence of the systems. The article attempts to show corporate governance as a broad and complex area that still contains many ambiguities. Different classifications of corporate governance models have been presented, but most attention is given to the Anglo-American and Continental-Japanese models. Then the crucial factors implying convergence and divergence of corporate governance systems are indicated. It was found that states try to unify the systems mainly in the field of legal regulations, but they pay little attention to achieving convergence in practice. Japan was used as an example of a country that retains its cultural identity under the conditions of the Americanization of regulations. Culture and tradition are the main obstacles to the convergence of corporate governance models. In order to achieve the research objective, a critical analysis of the subject literature and the appropriate legal regulations was used.