Yet it does attempt to improve Germany's two-tier board system in particular, by making supervisory boards better guardians of shareholders' interests, despite the presence on these boards of workers' representatives and ex-managers.

ECONOMIST: German companies

This is in contrast to the two-tier boards of German companies, which have an executive management board overseen by a non-executive supervisory board.

ECONOMIST: America has Sarbanes-Oxley. Britain has Derek Higgs