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Specifics of Anglo-Saxon and Continental corporate governance This thesis deals with the comparison of Anglo-Saxon and Continental approaches to corporate governance. Although the title of this thesis might evoke that the main theme of this thesis is a comparison of two different models of corporate governance, the basis for this work is the opposite. The author aims to make use of the compari- son of selected corporate governance issues in the various legal systems of both the Anglo-Saxon and Continental models of corporate governance to find out how sig- nificantly the current Anglo-Saxon and Continental model of corporate governance differs, whether there is a convergence or divergence between these two models and whether it makes sense to divide legal systems' approaches to corporate governance on the basis of these two models or not anymore. The thesis is divided into five (5) chapters, where the first chapter is a brief intro- duction to corporate governance issues followed by chapters dedicated to selected issues of corporate governance in joint-stock companies after. These four (4) main issues explored in the thesis are: the internal organization of the administrative bod- ies of joint-stock companies, the independence and objectivity of the corporation's administrative bodies, the... |
