ABSTRACT
The United Kingdom has been most commonly associated with a principles-based approach to corporate governance, and the establishment and regulation of standards of business conduct. The distinction and its implications for understanding the corporate governance regime is one that has been overlooked by United States comparative governance scholarship, which has, in its analysis of convergence trends, tended to treat the regimes in the United States and the United Kingdom as highly aligned. In fact, the United Kingdom was one of the nations to establish rules for the operation of companies and a legal framework within which business operates. The law governing corporations in the United Kingdom has become increasingly prescriptive in decades and the enactment of the Companies Act 2006 heralded significant reforms and interventions with respect to the operation and oversight of publicly listed companies and the most significant changes to company law.
