Модели корпоративного управления: опыт зарубежных стран и России.

COMPARATIVE ANALYSIS OF CORPORATE GOVERNANCE MODELS IN RUSSIA AND DEVELOPED MARKET ECONOMIES

Different corporate governance models around the world are discussed in the paper. They differ according to the variety of capitalism and corporate legislation in which they are embedded. There are also important differences between the approaches to governance issues in different countries. Each model has specific features, distinct competitive advantages and disadvantageswhich are presented and analyzed in the paper. The intricate shareholding structures of keiretsus in Japan, the heavy presence of banks in the equity of German companies, the chaebols in South Korea, family companies in Canada and Sweden, flexible regulation of corporate governance in USA and UK are examples of arrangements which try to respond to corporate governance challenges in the modern world. The peculiarities of the Russian developing corporate governance model are presented in the last part of the paper. The complexity of Russian legal environment, implications of the latest government initiatives and contemporary trends of Russian corporate governance are analyzed.