A Critique of Shareholder Value
- The Cournot Centre series
3. The convergence of the European model in question The previous chapter led us to reject the ‘end of history’ thesis from a normative point of view, in its designation of shareholder value as the optimal form of corporate governance. In the present chapter, we examine this thesis from an empirical perspective. At present, according to Hansmann and Kraakman (2001), it should be possible to observe an international convergence of governance towards the US model, favourable to minority shareholders. The continental European model in particular is claimed to be losing its speciﬁcities, drawing closer to the standards prevalent in the United States. It is this diagnosis, widely shared by theorists, that we subject to critical examination. We limit our analysis to the German and French cases, as they are characteristic of the continental European model. The period studied is the 1990s, during which the rise of ﬁnancial markets, supposedly at the origin of transformations in forms of governance, was most prominent. In the ﬁrst part of this chapter, we present the US, German and French models and underline their principal diﬀerences.1 We aim to highlight the elements that make up these models, as brought out by the comparative literature on this subject. In the second part of the chapter, we appraise the way in which current transformations in the ﬁnancial sphere are reshaping these elements. We also focus our attention on movements outside the ﬁnancial sphere that may either reinforce or weaken the continental European model. It is...
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