为防止董事、经理损害公司利益，各国对董事、经理竞业行为大都予以禁止或限制。禁止或限制的范围，有的为其任职公司“营业范围内”的行为，如日本、我国台湾地区；有的为其任职公司“同类的营业”，如我国、德国。①各国禁止或限制董事、经理自营及董事、经理为他人利益从事 In order to prevent directors and managers from harming the interests of the company, all countries prohibit or restrict the non-competition of directors and managers. Prohibited or limited scope, and some for his company “business” activities, such as Japan, Taiwan, China; some for their company “similar business”, such as China, Germany. (1) Each country prohibits or limits the self-employment of directors and managers and the directors and managers in the interests of others