COMPARATIVE ANALYSIS OF CORPORATE GOVERNANCE MODELS

Abstract

The article is devoted to the study of models of corporate governance in corporations. The purpose of the article is a comparative analysis of corporate governance models of different countries of the world. The main research methods that were used in the article are general scientific methods of analysis and synthesis, as well as comparative analysis, which became the basis for obtaining research results. The main features of the Anglo-American, Japanese, and German models of corporate governance were established in the conducted research, as well as their common features and differences. It was established that the main features or elements that distinguish one model from another are: the main participants of the corporate environment; main groups of shareholders of a specific country; composition of the board of directors (or boards, as in the German model); legislative framework; information disclosure requirements for corporations included in prelisting; corporate actions that require shareholder approval; the mechanism of interaction between the main participants.