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比较研究发现,不同的模式在特定的环境下都发挥了较好的作用:以英美为代表的单层制模式,以其内生制衡机制较好地解决对董事会和经理层的监督;以德国为代表的双层制模式,以强法律与弱权力相匹配的制衡机制,也有监督力;日本特色的混合制模式也富有成效。而中国平行的二元制董事会治理模式,未能发挥有效监督作用。解决的根本措施是强化监事会职能和完善独立董事制度。
Comparative studies have found that different models play a good role in specific circumstances: the single-tier model represented by the Anglo-American system, with its endogenous checks and balances mechanism to better solve the oversight of the board of directors and the manager; with Germany As the representative of the double system model, with strong law and weak power to match the checks and balances mechanism, but also supervisory power; Japanese hybrid model also fruitful. However, the parallel dual system of board governance in China failed to play an effective supervisory role. The fundamental solution is to strengthen the supervisory board functions and improve the system of independent directors.