Comparing Corporate Governance Systems
December 1969 - October 2005
Joint Project of the DIJ and J-IRIS
The question of what motivates managers, and who controls them, arises in each and every economic system as soon as management and ownership are separated. But, as can be seen very quickly, concrete characteristics are quite different: while in the U.S. and Great Britain the shareholders' interests are given priority, Japan and Germany were often seen as stakeholder-oriented. But of course, the often-stated superiority of the Anglo-Saxon model has been questioned - at least since the Enron and Worldcom scandals. On the other hand, the German and the Japanese model are not perfect either: one only has to think about the Japanese banking crisis or the hostile takeover battle of Vodafone and Mannesmann.
Having this in mind, efforts to reform the systems are understandable and visible: there are the Sarbanes Oxley Act in the U.S., the German Corporate Governance Code, or the revision of the Commercial Code in Japan, which is only the beginning of a substantial reform agenda.
Here also is the starting point for the joint project. Together with SEKI Takaya, Head of Corporate Governance Research at J-IRIS (a part of the Mizuho group) Andreas Moerke is interviewing members of the German Corporate Governance Commission: not only Professor Dr Baums, University of Frankfurt, Professor Dr Seibert, Ministry of Justice, and Professor Dr von Werder from the scientific community, but also practitioners like Dr Cromme, head of ThyssenKrupp's Supervisory Council, Dr Breuer and Mr Kopper, both of whom, during their interviews, were head of the Supervisory Council of Deutsche Bank.
Findings of these interviews are used for discussions with Japanese colleagues and lead to several publications and reports, for instance a special report for the Japanese Ministry of Economy, Trade and Industry. Further, a translation of the new German Corporate Governance Code into Japanese is to be published and made open on the Internet soon. Both project partners will join forces in an international symposium entitled "Comparing Corporate Governance Systems" to be held in Autumn 2003 in Tokyo.
The project is closely connected with another one: dealing with "Corporate Governance in Young Enterprises" (joint project of DIJ and Meiji University School of Commerce).
SEKI Takaya, Head of Corporate Governance Research
web: http://www.j-iris.com/english/corporategovernance.html )
Sābensu Okusurē hō to Doitsu kigyō no taiō [The Sarbanes Oxley Act and German Companies' Reaction]
In: Torishimariyaku no hōmu, Jan. 2003 Shōji Hōmu. pp. 86-87.