一、董事自我交易规制模式关于董事自我交易,不管是在大陆法系的法国,还是英美法法系的美英,都受到了严格的规制。纵观各国立法,虽然在董事自我交易的具体范围认定、正当程序、实体审查、责任追究等方面各有不同,但是基于其调整对象的一致性(也就是董事自我交易),各国立法在规制模式上体现出相当的一致性。从体系上看各国的规定都会有对董事自我交易的认定,这是规制的基础。从立法的发展来看,从董事自我交易的绝对禁止到其后的有条件的允许,各国已经认识到 I. Regulatory Model of Directors’ Self-dealing With regard to the self-dealing of directors, whether in the civil law system of France or the Anglo-American legal system in the United States and Britain, they are subject to strict regulations. Throughout the legislation of each country, though there are differences in the specific scope of self-dealing of directors, due process, substantive examination and accountability, based on the consistency of the object of adjustment (that is, self-dealing of directors) On the show a considerable consistency. From the system point of view, the regulations of all countries will have the self-dealing of directors, which is the basis of regulation. From the point of view of the development of the legislation, from the absolute ban on self-dealing of directors to the subsequent conditional permission, all countries have come to realize