Differentiates market (e.g. USA) from group‐based (e.g. Germany) corporate governance systems, traces their evolution and asks whether they are converging. Puts forward a theoretical convergence model based on the belief that agency problems can best be solved by specific corporate control mechanisms, recognizing that it would demand more changes from group‐based than from market systems. Examines current trends for both relating to institutional/regulatory environments, the market for corporate control and the focus on shareholder value creation/activism. Presents statistics from the USA, UK, Germany and France to show their trends towards the convergence model and discusses them in some detail. Concludes that they have all moved towards the model although in different ways and at different rates.
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