ABSTRACT
According to Lucian Cernat the convergence process towards Anglo-Saxon “best practices” is driven by the interrelated forces of liberalized international fi nancial markets which make it diffi cult to resist their shareholder orientation, and the European Union’s project to promote harmonization towards important features of the Anglo-Saxon system of capital markets. Paradoxically, the Europeanization project with regard to labor relations has the objective of developing the Continental model of worker representation in corporate governance. Cernat suggests the two central categories of corporate governance mechanisms are capital-related and labor-related, and that in Europe these two policies are essentially engaging in a contest, the outcome of which will determine the future direction of development of corporate governance in Europe. The capital-related characteristics include ownership structure, disclosure, voting, and the role of institutional investors. The laborrelated characteristics include the stakeholding position of labor, employee involvement, participatory management and codetermination.
