While post-scandal reforms in the USA, UK and Australia were prompted by similar motivations, interesting differences in terms of their focus and structure still resonate in current corporate governance debate. The unique contours of the various regulatory responses challenge not only the traditional convergence hypothesis, but also the idea that a unified common law corporate governance model exists. Rather, a fluid, dynamic and increasingly fragmented picture of corporate governance has emerged. Within this developing corporate governance framework, various jurisdictions are able to test regulatory techniques and learn by their own trial and error, and that of other jurisdictions.
- Sarbanes-Oxley Act
- capital market regulations
- corporate social responsibility
- corporate governance