Corporate Governance in the European Union: Firm Nationality and the 'German' Model

While there has been some convergence in corporate governance codes and securities regulations across the European Union (EU), the remaining areas of divergence are the most contentious as they reflect differences in fundamental societal norms and values. I propose that using the multinational corporation as the referent unit of analysis yields a means for making a qualitative distinction between the two regimes. I suggest that at least for firms with EU-wide scope, certain critical elements of the German model may be more appropriate, as the neoclassical justifications of the Anglo-American model are less reliable in such a setting.