"Comply or Disclose" Vis-À-Vis "Comply or Explain". A Critical Comparison of the Current US and UK Corporate Governance Approaches

Submitted Assignment , 2023 , 20 Pages , Grade: 77

Politics - Topic: Public International Law and Human Rights

This essay compares and contrasts the current corporate governance approaches in the US and the UK, two countries that share a common legal origin but have developed different regulatory frameworks. It examines the main features and differences of the US “comply or disclose” approach and the UK “comply or explain” approach, focusing on the aspects of board structure, shareholder rights, executive compensation, regulatory frameworks, and Corporate Social Responsibility (CSR). It evaluates the strengths and weaknesses of each approach, and their impact on the effectiveness of corporate governance in each country. It concludes that while both approaches have merits and demerits, the UK approach tends to be more flexible and stakeholder-oriented, while the US approach tends to be more rigid and shareholder-centric.

Inhaltsverzeichnis (Table of Contents)

• 1.0 INTRODUCTION.
• 2.0 LITERATURE REVIEW ON CORPORATE GOVERNANCE APPROACHES
  • 2.1 OVERVIEW OF US CORPORATE GOVERNANCE APPROACH
    • 2.1.1 Regulatory Framework.
    • 2.1.2 Shareholder Rights.
    • 2.1.3 Financial Reporting..
    • 2.1.4 Shareholder Primacy.
    • 2.1.5 Market-Driven Approach...
  • 2.2 OVERVIEW OF UK CORPORATE GOVERNANCE APPROACH
    • 2.2.1 Regulatory Framework.
    • 2.2.2 Stakeholder Approach....
    • 2.2.3 Strategic CSR..
    • 2.2.4 Executive Remuneration
    • 2.2.5 Shareholder Activism.....
  • 2.3 DISTINCTION BETWEEN US AND UK CORPORATE GOVERNANCE APPROACHES.
    • 2.3.1 "Comply or Disclose" Corporate Governance Approach in the US..
    • 2.3.2 "Comply or Explain" Corporate Governance Approach in the UK..
• 3.0 LIMITATIONS OF THE STUDY.
• 4.0 CRITICAL COMPARISON OF US AND UK CORPORATE GOVERNANCE.
  • 4.1 BOARD STRUCTURE AND COMPOSITION.
  • 4.2 SHAREHOLDER RIGHTS AND ACTIVISM..
  • 4.3 EXECUTIVE COMPENSATION
  • 4.4 REGULATORY FRAMEWORKS..
  • 4.5 CORPORATE SOCIAL RESPONSIBILITY
• 5.0 CONCLUSION.

Zielsetzung und Themenschwerpunkte (Objectives and Key Themes)

This essay aims to critically compare current corporate governance approaches in the US and UK, focusing on board structure, shareholder rights, executive compensation, regulatory frameworks, and Corporate Social Responsibility (CSR). It seeks to examine the differences in approaches, highlighting their impact on the overall effectiveness of corporate governance in each country.

• US and UK corporate governance approaches
• Board structure and composition
• Shareholder rights and activism
• Executive compensation
• Regulatory frameworks

Zusammenfassung der Kapitel (Chapter Summaries)

The essay begins with a literature review on corporate governance approaches, providing an overview of the US and UK corporate governance approaches, including their regulatory frameworks, board structures, shareholder activism, and executive compensation. The review highlights the importance of these factors in ensuring effective corporate governance.

The essay then provides a critical comparison of the US and UK corporate governance approaches, highlighting the similarities and differences in board structure, shareholder activism, executive compensation, regulatory frameworks, and CSR. The focus is on the different emphases placed on shareholder profit and market efficiency in the US, versus a stakeholder-based approach in the UK.

Schlüsselwörter (Keywords)

The essay explores the concepts of corporate governance, shareholder primacy, stakeholder approach, "Comply or Disclose" and "Comply or Explain" frameworks, board structure, shareholder activism, executive compensation, regulatory frameworks, and Corporate Social Responsibility (CSR) in the context of US and UK corporate governance.

• College: University of East London
• Course: INTERNATIONAL CORPORATE GOVERNANCE
• Grade: 77
• Author: Brian Khisa (Author)
• Publication Year: 2023
• Pages: 20
• Catalog Number: V1420492
• ISBN (PDF): 9783346973399
• ISBN (Book): 9783346973405
• Language: English
• Tags: Corporate Governance, US, UK, Comply or Disclose, Comply or Explain, Board Structure, Shareholder Rights, Executive Compensation, Regulatory Frameworks, CSR