随着信托业的逐渐盛行,越来越多的人将董事与公司之间的关系看作是一种信托关系,随之产生的董事义务也不言而喻。但鉴于英美法系与大陆法系本身的区别,美国与我国公司法中关于董事的义务也相应不同。本文将从中美两国董事主要的两种义务比较着手,希望通过借鉴和探究来完善我国公司法中的董事义务。 With the gradual prevalence of the trust industry, more and more people regard the relationship between the directors and the company as a kind of trust relationship, and the ensuing obligations of directors are also self-evident. However, in view of the difference between Anglo-American law system and civil law system itself, the obligations of directors in the United States and in our country are also different. This article will proceed from the two main obligations of the directors of China and the United States in the hope of improving the duties of directors in our company law through reference and inquiry.