Introduction

In this chapter we give a brief overview of corporate governance in the USA, the UK and Canada, while we deal with the OECD principles of corporate governance and corporate governance in Germany, China and Japan in Chapter 13. In the first edition of this book we dealt with the OECD principles of corporate governance and corporate governance in the USA, the UK and Germany in one chapter (Chapter 12). As we decided to add China and Japan as two new and important jurisdictions, the chapter became too long. The reason for the split is that corporate governance in the USA, the UK and Canada is classified as Anglo-American models. The OECD principles include traditional Anglo-American corporate governance principles, but it also goes wider – spanning across principles applying to a traditional unitary board structure and principles applying to a typical two-tier board structure. Germany has always been seen as the prime example of a jurisdiction that adopted a true two-tier board structure for public corporations and larger proprietary companies, while Japan has been influenced by this. China has a unique corporate governance model because of the political model adopted in that country.