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PERSPECTIVES AND OBSTACLES OF THE SHAREHOLDER ACTIVISM IMPLEMENTATION: A COMPARATIVE ANALYSIS OF CIVIL AND COMMON LAW SYSTEMS
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Alexander Kostyuk 
, Khurram Parvez Raja
Abstract
The paper outlines shareholder activism development in common law and civil law countries and identifies features of these legal systems that create preconditions and obstacles for shareholder activism. Our findings show that tendencies of shareholder activism depend on the type of the legal system, but also vary within the countries that share the same legal system. Thus, we conclude that the type of legal system is not the chief determinant of shareholder activism. A comparative analysis of shareholder activism in Germany and Ukraine (civil law countries) and the USA and the UK (common law countries) shows that the system of domestic corporate regulation, development of the stock market, companies’ capitalization and corporate governance influence the development of shareholder activism in equal measure.
Keywords: Shareholder Activism, Common Law, Civil Law, Hedge Funds, Corporate Governance
How to cite this paper: Raja, K., Kostyuk, A. (2015). Perspectives and obstacles of the shareholder activism implementation: A comparative analysis of civil and common law systems. Corporate Ownership & Control, 13(1-5), 520-533. https://doi.org/10.22495/cocv13i1c5p1
