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Bad Apples, Bad Oranges

其他書名	A Comment from Old Europe on Post-Enron Corporate Governance Reforms
出版	SSRN, 2003
URL	http://books.google.com.hk/books?id=tnbTzgEACAAJ&hl=&source=gbs_api

註釋Corporate scandals have hit on both sides of the Atlantic, but the public's reaction to them has been much stronger in the United States than in Europe. This comment first speculates on what accounts for this difference in the reaction on the two continents. Part III provides an account of recent corporate law reform initiatives within the European Union, highlighting the ways in which the Sarbanes-Oxley Act is often used as a model for reform. Part IV then reflects upon the increasing emphasis which reform initiatives place on independent directors, questioning whether it is realistic to expect so much from them in terms of improved governance and management of listed corporations. Part V concludes that the similarity of reform initiatives in Europe and in the United States appears to overlook the differences in corporate ownership between continental Europe on the one hand, and the United States and the United Kingdom on the other.