Wednesday, January 2, 2013

Part 2 -Corporate governance and director's duties- Comparative study


Board composition and remuneration of directors
3. What is the management/board structure of a company? In particular:
·         Is there a unitary or two-tiered board structure?
·         Who manages a company and what name is given to these managers?
·         Who sits on the board(s)?
·         Do employees have a right to board representation?
·         Is there a minimum or maximum number of directors or members of the managerial and supervisory bodies?
France

Law stated as at 01-Apr-2011
Board structure
The governance of an SA can be organised as a unitary or a dual structure.
Unitary structure. This most widely-used structure consists of a board of directors (conseil d'administration), headed by a chairman and a chief executive officer (CEO) (directeur général) who runs the company. Both positions can be held by the same individual.
Dual structure. This structure consists of a management board (directoire) composed of up to five members running the company, and a supervisory board (conseil de surveillance) that oversees the management board. The management board's members and its chairman are appointed and dismissed by the supervisory board, whose members are appointed by the shareholders.
Management
Unitary structure. The CEO, appointed by the board of directors, manages the company. He may be assisted by one or several deputy CEOs (directeurs généraux délégués), also appointed by the board.
Dual structure. The management board carries out the day-to-day management.
Board members
Unitary structure. The board of directors consists of three to 18 directors appointed by a shareholders' meeting and of employees' elected representatives. Directors can be individuals or legal entities (which must designate a permanent representative, subject to the same obligations and liabilities as an individual). The statutory auditor attends board meetings when the board approves the accounts, otherwise his attendance is optional.
Dual structure. The supervisory board consists of individuals or legal entities (except for its chairman) appointed by a shareholders' meeting and employees' representatives. The management board consists exclusively of natural persons elected by the supervisory board.
Employees' representation
In companies having over 50 employees, workers' council representatives sit on the board without voting rights.
In listed SAs where employees hold more than 3% of the share capital, one or more representatives must be elected to the board by the shareholders. These directors have the same status, obligations and liabilities as other directors.
Unlisted SAs' bye-laws may also authorise employee-elected directors to sit on the board without voting rights. The maximum number of such directors is four (or five for listed companies) and cannot exceed one-third of the total number of other directors. Employee directors have the same status, obligations and liabilities as directors appointed in shareholders' meetings.
Number of board members
Unitary structure. The number of directors is set in the bye-laws and must be between three and 18 (24 following a merger of SAs).
Dual structure. The management board consists of up to five members for an unlisted company or seven for a listed company. The number of supervisory board members is set in the bye-laws and must be between three and 18 (24 following a merger of SAs).
Employee-elected representatives are not taken into account for the calculation of the total number of directors.
Germany
Law stated as at 01-Apr-2011
·         Structure. Contrary to most corporate entities existing in Europe, German AGs have a two-tier board structure where the management board (Vorstand) conducts daily business of the company and the supervisory board (Aufsichtsrat) controls the management board. The influence of the shareholders' meeting is limited.
·         Management. The management board of an AG manages the company and conducts the daily business. The management board has extensive competences and is generally not subject to instructions by any third party, in particular the shareholders' meeting.
In a GmbH, the managing directors conduct the daily business of the company while the shareholders' meeting supervises the directors and is competent for any decisions outside the ordinary course of business.
·         Supervisory board members. The supervisory board consists of board members that are strictly separate from the management board. They advise and supervise the management board.
·         Employee representation. The AktG generally provides that the supervisory board members are elected representatives of the shareholders. However, several co-determination regulations exist so that employees have numerous rights for representation on the supervisory board, depending on the size of the company and the industry it operates in. In companies with 500 or more employees, one-third of the supervisory board is staffed with employees' representatives. In companies with more than 2,000 employees, the supervisory board is staffed with the equal number of the employees' and the shareholders' representatives.
·         Number of directors or members. The management board can consist of just one person, with no maximum number defined. If the registered capital of the company exceeds EUR3 million, the management board must comprise at least two members. The DCGK recommends that the management board should have several members and one chairman (Vorstandsvorsitzender). The minimum number of supervisory board members goes from three up to 21, depending on the registered capital of the company and, for co-determined companies, on the number of employees.
India
Law stated as at 01-Apr-2011
·         Structure. The board structure is unitary.
·         Management. A company is managed by its board. Every public company or a private company which is a subsidiary of a public company with a paid-up share capital of more than INR50 million (as at 1 April 2011, US$1 was about INR45) must have a managing director or whole-time (full-time) director or manager for managing the affairs of the company. A private company may or may not have a managing director. (For the appointment of independent directors, see Question 5, Independence.)
·         Board members. The board of a public company comprises management directors, representatives of shareholders and independent directors. A private company's board comprises shareholders' representatives. A private company may or may not have independent directors or a management director.
·         Employees' representation. There is no mandatory requirement for employees' representation on the board.
·         Number of directors or members. A private company must have a minimum of two directors and two members, whereas a public company must have a minimum of three directors and seven members.
The Netherlands
Law stated as at 01-Dec-2012                     
The current CGC entered into force in 2009 (amended 2008). The CGC contains a non-binding list of principles and best practices for listed companies.
The areas covered in the CGC are divided into four main sets of principles relating to:
·         The management board (that is, its role and procedures, remuneration and conflicts of interest).
·         The supervisory board (that is, its role and procedures, independence, composition and expertise, the role of the chairman and company secretary, key committees, conflicts of interest, remuneration and one-tier board structure).
·         The shareholders and general meeting of shareholders (that is, their powers, depositary receipts for shares, information for and logistics of the general meeting, and responsibilities).
·         Auditing and financial reporting (that is, responsibility for financial reporting, the roles of internal and external auditor).
The CGC contains a set of principles and best practice provisions that regulate relations between the management board, the supervisory board and the shareholders. The CGC applies to all:
·         Companies whose registered offices are in The Netherlands and whose shares or depositary receipts for shares have been admitted on a stock exchange (foreign or in The Netherlands), or more specifically to trading on a regulated market or a comparable system.
·         Large companies (that is, balance sheet value more than EUR500 million) whose registered offices are in The Netherlands and whose shares or depositary receipts for shares have been admitted to trading on a multilateral trading facility or a comparable system.
For the purposes of the CGC, holders of depositary receipts issued with the co-operation of the company (met medewerking van de vennootschap, bewilligde certificaten) are treated similar to shareholders.
The general principles concerning good corporate governance contained in the CGC can also apply to non-listed companies. These companies can voluntarily apply the CGC.
Listed companies must publish a statement on their corporate governance (DCC and Corporate Governance Decree of 23 December 2004 (amended 1 April 2009) implementing EU directives). This corporate governance statement may be incorporated in the annual report, added as an appendix or electronically published separately with reference to the annual report. The following elements must be addressed in the report:
·         Compliance with the principles and best practices of the CGC.
·         Main characteristics of the internal risk management and control systems connected with the company's financial reporting process.
·         Functioning of the general meeting and its primary powers and the rights of shareholders.
·         Composition and performance of the management board and the supervisory board and its committees.
·         Participations in listed companies.
·         Special control rights attached to shares and the parties entitled to those rights.
·         Limitations of voting rights.
·         Appointment and replacement members of the management board and supervisory board.
·         Powers of the management board and supervisory board, specifically regarding the issuance and redemption of company shares.
·         List of names of persons with special control rights under the articles and the characteristics of those rights.
The CGC is based on the comply or explain principle. Deviation from the principles and best practice provisions of the CGC is allowed, but must be duly explained in the company's annual report.
The corporate governance statement must be reviewed by the registered accountant as part of its review of the annual account. The accountant verifies:
·         Whether the statement is present.
·         Whether the statement addresses the principles and best practices.
·         The presence of an explanation in cases of deviation from these principles.
·         The presence of other subjects that need to be reported in the annual report regarding corporate governance but which are not part of the corporate governance statement.
However, the accountant does not materially review the statement or explanations, except for a marginal check on consistency with the financial reporting.
The Committee on Corporate Governance (Committee) annually reviews the compliance of listed companies with the CGC and reports its findings to the government. Its reports are made public on www.commissiecorporategovernance.nl. The Committee recommends that a listed company sets out its general corporate governance structure and the extent of its compliance with the CGC. Participation in the annual review of the Committee is mandatory for listed companies.
Although the CGC is not mandatory, non-compliance with its principles or best practice provisions that are in line with statutory provisions under the DCC forms a direct breach of the CGC. In addition, a breach of the CGC may:
·         Lead to a breach of the principle of reasonableness and fairness.
·         Form the basis for specific corporate legal proceedings, such as inquiry proceedings.
The Committee indicated in its Annual Report 2011 that the CGC is increasingly supported by directors of listed companies with a relatively high level of compliance. However, explanation of why certain principles are not complied with is sometimes insufficient and a number of material changes must still be made (for example, term in office, severance bonus, composition of the supervisory board to reflect a more balanced male/female ratio). The Committee also observes an increasing awareness of (institutional) shareholders of their own responsibility in using their voting rights. In addition, the Committee finds that non-listed medium and small sized companies are progressively implementing the CGC. However, these companies are not formally obliged to do this.
UK (England and Wales)
Law stated as at 01-Apr-2011
·         Structure. UK companies operate a unitary board structure. Directors may, however, be executive or non-executive. The former are employees of the company with specific duties as full-time managers; the latter are not employees of the company and often commit to devoting a few days a month to attend board and committee meetings. The role of the non-executive director is commonly seen as to provide a constructive challenge to the executive directors and to help develop the company's strategy. Non-executive directors can also sit on committees of the board to deal with areas such as remuneration of directors, nominations to the board and audit and risk.
The Companies Act 2006 makes no distinction between executive and non-executive directors and treats both types of director as having the same obligations and liabilities.
·         Management. The articles of most companies contain a provision along the following lines: "the directors are responsible for the management of the company's business, for which purpose they may exercise all the powers of the company".
While the full board may meet once a month or even less often, an executive committee, comprising the executive directors and other senior managers, may meet more frequently and have responsibility for the day-to-day management of the company's business. The exact terms of that responsibility and the powers the committee may exercise without reference back to the full board will be set out in the committee's terms of reference.
·         Board members. The directors of a company comprise its board. One of the board members, often a non-executive director, will be elected chairman.
·         Employees' representation. Employees do not have any right to board representation in a UK company. The articles of a company may require that a certain number of directors be drawn from the workforce and provide how they are to be selected, but that is not a common provision.
·         Number of directors or members. A private company must have at least one director and a public company must have at least two. A company's articles may increase those minimum numbers and may also set a maximum board size. A director does not have to be an individual. A company may serve as a director of another company, although every company must have at least one individual or natural person on its board.
United States
Law stated as at 01-Dec-2012
The US has not adopted a corporate governance code. In the US, corporate governance requirements are imposed primarily by various federal laws, including the Sarbanes-Oxley Act of 2002 (Sarbanes-Oxley Act), the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) and the federal securities laws, as well as regulations, rules and other guidance promulgated by the SEC.
In addition, the listing standards of registered stock exchanges require listed companies to maintain specified corporate governance practices.

4. Are there any age or nationality restrictions on the identity of directors?
France

Law stated as at 01-Apr-2011
Age restrictions
Unitary structure. Except when otherwise provided for in the bye-laws, the number of directors aged over 70 cannot exceed one-third of the total and the age limit for the chairman and CEO is 65.
Dual structure. Except when otherwise stated in the bye-laws, the number of directors aged over 70 cannot exceed one-third of the total and the age limit for members of the management board is 65.
Nationality restrictions
European citizens. Citizens of the EU and of Iceland, Liechtenstein, Norway and Switzerland are exempt from any formalities (except if resident in France, in which case they must complete local registration formalities).
Other non-French nationals. A national of any other country who wishes to become chairman, CEO, deputy CEO or chairman of the management board of a French company must:
·         If a resident of France, be in possession of a temporary residency permit (carte de séjour temporaire) authorising commercial and professional activities.
·         If a non-resident of France, file a declaration with the préfet of the administrative area in which the company's registered office is located.
Unless otherwise provided for in the bye-laws, these formalities are not required for:
·         A director who is not also the CEO.
·         Members of the management board not authorised to represent the company with third parties.
Gender restrictions
Listed companies. From 28 January 2011, if one gender is not represented on the board, one person of this unrepresented gender must be appointed at the next general meeting which has a director appointment on its agenda. By 1 January 2014, each gender must be represented by at least 20% of the board. By 1 January 2017, each gender must be represented by at least 40% of the board.
Unlisted companies. From 1 January 2017, for companies with revenues or a balance sheet over EUR50 million and employing at least 500 persons for three consecutive years (that is, in 2020), each gender must be represented by at least 40% of the board.
From 1 January 2017, if the board of directors consists of no more than eight members, the difference between the number of directors of each gender should be no higher than two.
Germany
Law stated as at 01-Apr-2011
Age restrictions
Members of the management or supervisory board cannot be less than 18 years old. There is no maximum age limit. However, the DCGK recommends an age restriction for both boards. Although the DCGK does not contain any specific age limit, age restrictions between 60 and 65 years for the management board and between 70 and 75 years for the supervisory board are common in practice.
Nationality restrictions
There are no legal nationality restrictions. On the contrary, the DCGK recommends that diversity should be considered when appointing the members of the management and supervisory boards.
India
Law stated as at 01-Apr-2011
Age restrictions
Generally, a director must be at least 18 years old. However, an independent director must be at least 21 years old and a managing director of a public company must be at least 25 years old.
There is no restriction on the maximum age of a director, except that a managing director of a public company cannot be older than 70 years.
Nationality restrictions
There are no nationality restrictions on the appointment of directors, except in certain sectors. For example, companies engaged in the telecommunications sector and the defence sector must have a majority of Indian directors, and companies providing security services (in the private sector) cannot have foreign directors.
The Netherlands
Law stated as at 01-Dec-2012
Amendments
The draft Amendment on the Rules on Management and Supervision (Amendment Management and Supervision) has been adopted and will enter into force as of 1 January 2013. This amendment legislation introduces the one-tier board for public and private companies, consisting of executive and non-executive directors (see Question 37). The answers below describe the current situation (2012) whereby only a two-tiered board is possible. Legislation making private companies more flexible (Flexible Private Company) has been adopted and is in force as of 1 October 2012, which amends a number of DCC articles (see Questions 14 and 37). The answers below take these amendments into account.
Structure
Dutch public and private companies must have a management board. The articles can provide for a two-tiered board structure with a management board and a supervisory board. A two-tiered board structure is mandatory for large companies (see Question 2). Although currently not expressly provided for in the DCC, it is possible to set up a management board to operate similarly to a one-tiered board under Dutch law. As of 1 January 2013 legislation will come into effect under which the one-tier board will be permitted under the DCC (see above, Amendments).
Management
The day-to-day management of a company is carried out by the management board. The name that is given to members of the management board is managing director (bestuurder).
Board members
The managing directors sit on the management board and the supervisory directors sit on the supervisory board. Managing directors cannot sit on the supervisory board. Supervisory directors cannot sit on the management board.
Employees' representation
Employees may have, but are not entitled to, board representation. In large companies, the works council can recommend candidates for the supervisory board. Unless the articles provide for a different procedure, the works council also has an "enforced nomination right" (versterkt aanbevelingsrecht) with regard to one-third of the members of the supervisory board (see Question 8, Appointment of directors).
Number of directors or members
If installed, the supervisory board must have at least one supervisory director, except for large companies, which must have at least three supervisory directors. Only natural persons can be appointed as supervisory directors. A management board must have at least one managing director. References to directors in this overview include management and supervisory directors, unless otherwise stated. There is no maximum number of directors.
UK (England and Wales)
Law stated as at 01-Apr-2011
Age restrictions
A director must be aged at least 16. There is no maximum age limit.
Nationality restrictions
There are no nationality restrictions for directors of UK companies.
United States

Law stated as at 01-Dec-2012
Structure
Corporations incorporated in the US almost always have a unitary board structure. Under most US state corporation statutes, the board members are elected for a term of one year. State laws commonly provide the option to institute a staggered or classified board, which ordinarily divides the members into three separate classes, with one class being elected annually to serve a three-year term. However, due to shareholder activism, classified boards have been declining in popularity over the past few years, with only 15 of the Top 100 US Companies having classified boards in 2012 compared to 37 of the Top 100 US Companies in 2006 (2012 S&S Corporate Governance Survey).
Management
The corporation’s board is responsible for appointing the corporation’s management. The board typically delegates the day-to-day operation of the business to a chief executive officer (CEO) and other management employees. The senior managers of the corporation generally include the CEO, the chief financial officer (CFO) and the chief accounting officer (CAO), among others.
Board members
Members of the board are generally independent directors or members of senior management of the corporation, although some boards have members who are non-executive directors who are not independent (such as former senior executives of the company). While state and federal laws do not, subject to certain limitations, govern director independence requirements, the NYSE Listing Manual and the Nasdaq Marketplace Rules require a majority of the board members to be independent. In 2012, independent directors constituted 75% or more of the boards at 93 of the Top 100 US Companies. The CEO was the only non-independent director at 56 of those Top 100 US Companies (2012 S&S Corporate Governance Survey).
Employees’ representation
Employees are not entitled to board representation except in rare circumstances, and employee board members are nearly always executive officers.
Number of directors or members
Most states do not require a minimum number of directors and leave the size of the board to be set by the corporation’s certificate of incorporation or bye-laws. The corporation’s certificate of incorporation or bye-laws usually set the minimum and maximum number of directors that can comprise the board and provides that the exact number be set out in the bye-laws or established by a board resolution. In 2012, the size of the board of the Top 100 US Companies ranged from eight to 17 members, with an average of 12 members (2012 S&S Corporate Governance Survey).

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