This text compares the corporate governance structures of the US quoted company and its European equivalent and the role which employees as non-shareholding stakeholders hold within those structures. It focuses on the incidents of ownership normally exercised by stakeholders and raises questions regarding different responses to the issue of mandated labour market regulation on both sides of the Atlantic. The text considers theoretical and practical issues raised in this context.
Irene Lynch-Fannon, Prof Emerita (UCC), is a graduate of UCD (BCL 1982); Oxford University (BCL 1986, Senior Scholar, Somerville College) and the University of Virginia (Doctor of Juridical Science 1999). She qualified as a Solicitor in Ireland in 1985.
Dr Lynch-Fannon was Chair of the Insolvency and Rescue Sub-Committee of the Compnay Law Review Group from 2012 to 2026 and a member of the EU Commission Committee of Experts on Insolvency and Rescue Law from 2020 to 2026.
Her publications include Corporate Insolvency and Rescue (2012) and Company Law: Fundamental Concepts and Doctrines (2026).
Marc Moore was appointed to the Chair in Corporate/Financial Law at UCL Laws in 2019. Prior to this, he was Reader in Corporate Law and MCL Director at the University of Cambridge, UK.
Christopher Bruner is a Professor of Law at the University of Georgia School of Law.