"Comply or Disclose" Vis-À-Vis "Comply or Explain". A Critical Comparison of the Current US and UK Corporate Governance Approaches

Submitted Assignment from the year 2023 in the subject Politics - Topic: Public International Law and Human Rights, grade: 77, University of East London, course: INTERNATIONAL CORPORATE GOVERNANCE, language: English, abstract: This essay compares and contrasts the current corporate governance approaches in the US and the UK, two countries that share a common legal origin but have developed different regulatory frameworks. It examines the main features and differences of the US "comply or disclose" approach and the UK "comply or explain" approach, focusing on the aspects of board structure, shareholder rights, executive compensation, regulatory frameworks, and Corporate Social Responsibility (CSR). It evaluates the strengths and weaknesses of each approach, and their impact on the effectiveness of corporate governance in each country. It concludes that while both approaches have merits and demerits, the UK approach tends to be more flexible and stakeholder-oriented, while the US approach tends to be more rigid and shareholder-centric.