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Abstract

While in the 1980s there was a considerable interest in the apparent strengths of the German and Japanese systems of corporate governance, in the mid to late 1990s proponents of the alleged virtues of the US model of corporate governance largely drowned out other voices. Both in Germany and in the USA, this discussion about the appropriate management and control of enterprises has been under way lately. The purpose of this article is to take a closer look at one of the mechanisms for controlling managers, namely the board structures. The comparison will focus on the ways in which the two systems differ from each other and if there is a model which serves the task of controlling the management board better.

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