ss a number of differences in the two countries in greater detail, with particular attention being paid to differences in the actions of institutional investors between the two countries. We then discuss the place of corporate social responsibility (CSR) issues in the UK and US, and argue that CSR issues are generally treated more seriously in the UK, across a broader spectrum of market participants, than in the US. We summarise our multi-level theoretical model which explores different motives that actors might have to ask firms to engage in CSR initiatives, and we apply this model to the action of institutional investors to explain the greater emphasis on CSR issues in the UK versus the US. We conclude with some suggestions for future research in this area.
Corporate governance systems in the UK and the US Stylised portraits of the Anglo-American corporate governance system emphasise the features shared by the US and the UK, including the primacy of shareholders as beneficiaries of fiduciary duties, the importance of equity financing, dispersed share ownership among uncommitted shareholders, active markets for corporate control as a mechanism of managerial accountability, and flexible labour markets (Jensen and Meckling, 1976; Hall and Soskice, 2001; Streeck and Yamamura, 2001). Some obvious qualifications are necessary to render this picture fully accurate. For instance, while neither the UK nor the US has concentrated individual block-holders, crossshareholdings or dominant family-owned firms in appreciable numbers, as do the Continental and Japanese systems (Shleifer and Vishny, 1997), institutional investors’ control of the equity market as a whole has grown rapidly in the last 20 years in both countries. Institutional investors controlled about 80 per cent of the UK equity market as of 31 December本
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www.51lunwen.org提供 2003 (Mallin et al ., 2005, 535), and close to 60 per cent of the US equity market in 2003 (Binay, 2005, 127). As a result, institutional investors have the potential to exercise coordinated, collective power (Clark and Hebb, 2004; Clark and Wojcik, 2005). How institutional investors act on this potential is quite different in the two markets, as will be discussed below. The point here is simply that, because of the significance of institutional investors, the conventional model’s sharp contrast between the shareholder dispersion in the Anglo-American world and block shareholding in Continental Europe is overstated (Mallin et al ., 2005, 536).
Important differences between core aspects of the corporate governance systems in the UK and the US are summarised in Table 1. Recognising that firms are situated within a given society and political tradition, which will influence the decisions of individuals within the firm, one can conceptualise corporate governance as relationships within the firm and between the firm and its environment (i.e. society). Figure 1 illustrates this concept. While there are a number of relationships that define the corporate governance system within any given country (Aguilera and Jackson, 2003), two particularly important ones are that between the Chief Executive Officer (CEO) as a key actor within the top management team (TMT) and the board of directors, as an indicator of internal governance relationships; and that between the firm and its equity investors as an indicator of external governance relationships. Each of these relationships shows a divergence that is occurring between
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