While it is not the primary objective of this article to discuss differences between national codes, a number of distinguishing characteristics nevertheless bear mentioning. A first important variable is the scope of corporate governance codes or recommendations. Naturally, most codes examined for this article (and in most other member countries) address issues such as the equitable treatment of shareholders, operation and accountability of boards and management, transparency and disclosure, as well as minority shareholder protection. However, while a number of corporate governance codes and recommendations purport to have been modelled after the OECD Principles of Corporate Governance, they differ.
