Reform, Financial Systems and Legal Frameworks
The CRC Series on Competition, Regulation and Development
Edited by Thankom Gopinath Arun and John Turner
Chapter 3: The Anglo-American Model of Corporate Governance in Sub-Saharan Africa: Explanatory and Normative Dimensions
Royston Gustavson, Nicholas Ndegwa Kimani and Donald Atieno Ouma INTRODUCTION In sub-Saharan Africa, the corporate governance1 model that has been adopted is the so-called ‘Anglo-American’ (that is, British and US) model. Although there has been much discussion in both the literature and amongst business leaders of this model, there is no precise definition of what Sub-Saharan Africans understand this term to mean, nor is there any consensus other than that it is a unitary board model. While it cannot be doubted that good corporate governance adds value to a corporation, the authors of this paper believe that corporate governance needs to be deconstructed (Gustavson et al., 2005). We are aware that a substantial amount of work is being done in the area of establishing legal and institutional arrangements for corporate governance in Africa, especially by governments and regulatory agencies (Armstrong, 2003, 2006). We are also aware of the contributions of other sets of actors, such as the Kenya-based Centre for Corporate Governance (which operates throughout East Africa), or the Institute of Directors in Southern Africa under the auspices of which the King Committee on Corporate Governance was initiated. Corporate governance also plays an important role in the African Peer Review Mechanism, but although the purpose of corporate governance is given (NEPAD, 2004: 59),2 there is no discussion of the model of corporate governance. While there has also been empirical research on how the model is being implemented within sub-Saharan African countries (see for example Goldsmith, 2003), 23 24 Corporate...
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