The concept of "corporate governance", which has appeared in the United States, is however recently subject to vivid discussions across the world. The notion is understood differently in distinct jurisdictions. Nevertheless, corporate governance widely refers to the way corporations are managed. The present study firstly concentrates on the United States since the latter has been the first country to host debates on the topic. Different governance models basically distinguish the North-American and European (Continental Europe) governance systems. However, debates in the United States and Canada concentrate on distinct issues. The third studied country, France has also its own characteristics. International organisations' initiatives on the topic such as the OECD, illustrate the importance given to "corporate governance". Although the uniformity of distinct national governance systems is not likely to be reached in the near future, certain similarities might be pointed at, especially through the recent activism of institutional shareholders.

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