“…Jacoby (2005) outlines the governance debate in terms of two distinct approaches; a "shareholder approach" (Jacoby, 2005, p 6), also called the Anglo-American approach for its prevalence in these countries, and a "stakeholder approach" (Jacoby, 2005, p 6) practised in countries such as Germany, France and Japan. The shareholder approach is characterised by an active equity market, which also serves as a source of corporate credit, legal protection for minority shareholders and a dynamic market for corporate control (Jacoby, 2005;O'Sullivan, 2003;Aguilera, 2005). In contrast, countries inclined to follow the stakeholder approach typically have large blocks of shares held by credit institutions or families, historic ties with employee organisations who are given a voice on the board and a less active market for corporate control (Jacoby, 2005;O'Sullivan, 2003).…”