Prof. Dr. Eva Maria Micheler – Legal Transplants and Corporate Governance

Some ten years ago Austria and Germany have adopted corporate governance codes. These codes were modelled after the English corporate governance code. The two codes and rules of corporate law based on these codes have become firmly established in the Austrian and German legal system. They have been absorbed into the national jurisdiction.

The presentation will examine the effect these transplants have had on Austrian and German law. Has the adoption of English corporate law rules led to convergence? Have the rules changed as a result of the transplantation? To what extent has Austrian and German law interpreted the transplanted rules in light of their origin?