Abstract
The most fundamental distinction among models of corporate governance is the one made between the shareholder and the stakeholder models. But in these times of globalization, the powerful growth of institutional investors has an increasing impact on how corporations function. One important question that arises is whether one particular national corporate governance system is better than another, and whether national governance systems will converge. If convergence does occur, does that mean that systemic differences will disappear, leaving only one model, or are we witnessing a dual convergence leading to a hybrid model, specific to each system according to the dependency path?
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