Standardization of Company Law in Germany, other EU Member States and Turkey by Corporate Governance Rules

Abstract

Corporate Governance rules are now contained in a multitude of Corporate Governance Codes worldwide. There are still different approaches concerning the implementation and enforcement of Corporate Governance codes in Europe. Besides the Corporate Governance Codes of Germany and other EU Member States, particularly the Combined Code in the UK, another very interesting Corporate Governance Code is found in Turkey's “Corporate Governance Principles” of 2003, amended in 2005. The “Principles” were established by the Capital Markets Board of Turkey. The Turkish “Principles” may become even more important in the near future, when the new Turkish Commercial Code will come into force. The article concludes with a discussion on how far a harmonization of Corporate Governance rules in Europe and worldwide should go, particular in view of the “path dependence” of Corporate Governance rules, for example concerning the diversity of board structures and remuneration models. It turns out that no single Corporate Governance model fits every country.