ABSTRACT
We […] have two principal and opposing systems of corporate governance. The US system considers the fi rm to be the object of property rights; the submission of this object to the interests of the shareholders is achieved in the fi rst place by the depth and liquidity of stock markets. The continental European model, on the contrary, is founded on a holistic or partnerial vision of the fi rm; company management is partially protected from the stock market by the stability of large blockholdings and by employee participation.
