近年来独立董事制度在中国发展得非常之快，但细究之，存在的缺陷也不少。相比较而言，英美独立董事制度在角色定位和激励机制、市场选择和声誉评价机制等架构方面较为成熟、较为有效，这或许对中国独立董事制度的健康发展不无裨益。监事的从属地位注定监事制不能充分有效发挥 In recent years, the system of independent directors has developed very rapidly in China. However, there are many shortcomings in the details. In contrast, the independent director system in the United Kingdom and the United States is relatively mature and effective in the structure of role orientation and incentive mechanism, market selection, and reputation evaluation mechanism. This may be beneficial to the healthy development of the independent director system in China. The subordinate position of supervisors is doomed that the supervisory system cannot be fully effective