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the operation, and the latter is responsible of supervision.
Japan and German shareholding structure is characterized by the relative concentration of ownership, and the major shareholders of listed companies to banks. The banks have significant corporate interest or stocks, and the management is under their strict supervision. Concentrated ownership incentives the investors and also give them power to supervise and control the managers.
Management structure in German companies is a unique two-tier board system including the Board of Supervisors and the Board of directors. The status of the Board of Supervisors is above it of the Board of Directors. The Board of Supervisors elected by general meeting of shareholders mainly supervises and manage the Board of Directors on behalf of the interests of the shareholders. But it is not directly responsible for the day-to-day operations, and its functions are equivalent to the chief executive officer in American companies. Nevertheless, Management structure in Japan companies consists of general meeting of shareholders, directorate, manager and independent controllers.  In fact, the general meeting of shareholders in the Japanese exists in name only, and it is the inside directorate that play the real role of decision-making. The members of the directorate are mainly from the company, and the company does not have independent exterior directors. So the common management has changed into management controlled by operators and insiders.
China's shareholding structure includes circulating and non-tradable shares. The proportion of the circulating shares is a bit of small and it of the non-tradable shares is a bit of large. The concentration of the shares of China's listed companies is generally rather high, which looks more like Germany and Japan model. Whereas, shareholding structure in China is essentially different from it in Germany and Japan. In China listed companies, the state-owned and corporate shareholders occupy the dominant position in controlling the shares. Moreover, these stocks are not listed shares in circulation. However, in Germany and Japan companies, it is the corporation shareholders consisted of financial institution and company corporations who occupy the dominant position. And these stocks are free circulating shares. In addition, the state-owned shareholder, as the largest shareholder in China’s listed companies, still exist a serious problem of lacking main body. These reasons make the shareholding structure of China’s listed companies is very different from it of German and Japan’s in both nature and characteristics.
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