公司治理结构的比较分析政治经济学专业论文.docx

哈尔滨工业大学经济学硕士学位论文 哈尔滨工业大学经济学硕士学位论文 - - II - Abstract Corporate governance structure is essentially a formal and informal institution of making incentive and constraint for manager, how to control “insider control”. How to stimulate and constrain manager are the core of the corporate governance . Theoretically, the models of shareholder sovereignty, managerial domination and co-governance of interested person have been formed; in practice, various governance structures of corporation, such as market-dominated structure adopted by Britain and America, bank-dominated structure adopted by Japan and Germany as well as family-controlled structure adopted by Korea, have come into being. One of the characteristics of corporate governance of our country is the governance model of “key person dominated structure”, which is a mixture of “market-dominated structure plus family-controlled structure” based on the governance model of shareholder sovereignty. Compared with the models of other countries, besides the common features, there do exist some unique traits and defects in our model, that is, the inside control mechanism of “key person” in which collusion becomes the most common strategy. The absence of many regulations and deficiency in our system have led to the emergence of collusion, in turn , collusion may aggravate the destruction of the system itself. Considering the actual participation of “key person” is the leading factor causing collusion. Institution innovation in order to constrain collusion becomes one of the effective measures to solve the serious problem of “insider control” in our country. In accordance with the global developing tendency of the corporate governance, series of corresponding system for controlling collusion should be established on the basis of emphasizing shareholder sovereignty during the process of innovation of corporate governance in our country. Thereby institution of co-governance of interested person accordingly domestic characteristic