Centre for Business Research, University of Cambridge, Working Paper No. 381
28 Pages Posted: 19 Jan 2009 Last revised: 30 Jan 2014
Date Written: May 29, 2009
This paper uses a new quantitative methodology ("numerical comparative law", "leximetrics") in order to answer the questions of whether there has been convergence, divergence or persistence of for shareholder, creditor, and worker protection, and how this development relates to the Common Law/Civil Law distinction. It is based on new indices which code the legal development of France, Germany, India, the UK and the US from 1970 to 2005. The main result is that one has to distinguish between different areas of law: the laws have converged in shareholder protection, they have diverged in worker protection and in creditor protection converging and diverging trends even out. These results do not depend on the distinction between Civil Law and Common Law countries, because there have been a number of instances where countries of different legal families have converged and countries of the same legal family have diverged.
A revised version of this paper was published under the title "Convergence in Corporate Governance: A Leximetric Approach", available at http://ssrn.com/abstract=1444860.
Keywords: shareholder protection, creditor protection, worker protection, comparative law, legal convergence, numerical comparative law, leximetrics
JEL Classification: G30, K00, K12, K31, N20, N40, P50
Suggested Citation: Suggested Citation
Siems, Mathias M., Shareholder, Creditor and Worker Protection: Time Series Evidence about the Differences between French, German, Indian, UK and US Law (May 29, 2009). Centre for Business Research, University of Cambridge, Working Paper No. 381. Available at SSRN: https://ssrn.com/abstract=1329997 or http://dx.doi.org/10.2139/ssrn.1329997