Angleichung der Unternehmensverfassung in Europa - ein Forschungsprogramm

This paper discusses whether, in which respects, and to what extent the corporate governancesystems of Germany, the United Kingdom and France have already converged in the course ofEuropean economic integration, or are likely to converge in the foreseeable future. Wepresent, and attempt to provide empirical support for, the proposition that, firstly, as far aslegal and other regulation is concerned, a certain, though limited, degree of convergence idalready visible today. Secondly, as far as the practice of corporate governance is concerned,there is less convergence; and thirdly, as far as the systemic properties of the nationalcorporate governance systems are concerned, there is no convergence at all.In order to support our proposition, we first develop a methodology for describing andanalysing corporate governance systems and for identifying their systemic properties, andthen apply this methodology to the corporate governance systems of the three countries.The lack of systemic convergence so far seems to be due to the complementarity between thedifferent elements of the respective national financial systems. The paper therefore concludeswith the prediction that, if there is any substantial convergence of the corporate governancesystems in Europe in the foreseeable future at all, it is not likely to be a smooth transition to a"middle of the road" position located somewhere between the present German and Britishcorporate governance systems.