Comparative Corporate Governance | Petri Mäntysaari

This book is an analytical overview of the regulation of shareholder activism in the UK and Germany. At a more general level, the book shows how the comparative legal method can be used in the study of the corporate governance systems of different countries. The book deals with the regulation of the governance of listed companies within a wide framework that recognises the importance of company law, securities markets law, standards and internal rule-making. The author examines the fundamental similarities and differences between the regulation of corporate governance in these two jurisdictions and argues that the nature of German law is often misunderstood in corporate governance scholarship. The book is an essential resource for all those studying comparative corporate governance.