Corporate governance systems: comparative aspect

Abstract

The models of corporate governance system are analyzed in the article. Particular attention is paid to the corporate governance system of the USA, Germany in the aspect of the proposed changes to the company law of Ukraine. The place of the supervisory board in the Ukrainian corporate governance system is clarified. The author analyzes the advantages and disadvantages of a one-tier corporate governance system and concludes that the introduction of a one-tier corporate governance system will facilitate management flexibility and is in demand among foreign investors (primarily from the states of the Anglo-American law system). At the same time its implementation entails risks of oversight activities of management of the company. Therefore, the introduction of a one-tier system of governance in the corporate law of Ukraine requires further detailed scientific research.