Understanding Corporate Governance Reform in South Africa: Anglo-American Divergence, the King Reports, and Hybridization

This article investigates corporate governance reform in South Africa in the context of the country's international links with Anglo-American corporate governance and domestic pursuit of socioeconomic development. Two key questions are evaluated. (a) How has divergence within the Anglo-American model influenced corporate governance reform in South Africa? (b) Can South Africa's historical closeness to the Anglo-American model be combined with increasing attention to stakeholder issues to produce a hybrid "African model" of corporate governance? Evaluating these questions, the following issues are explored in turn: the contrast between shareholder and stakeholder models, divergence between U.S. and U.K. approaches to corporate governance as exemplified by Sarbanes-Oxley, locating a South African approach in context of the Anglo-American model, the King reports and an emerging "African" model of corporate governance, and the role of international and domestic factors in shaping South Africa's ongoing reform process.