Understanding corporate governance reform in South Africa: Anglo-American divergence, the King reports and hybridization

Stefan Andreasson, Queen's University - Belfast

Abstract

This article investigates corporate governance reform in South Africa in the context of the country’s international links with Anglo-American corporate governance and domestic pursuit of socio-economic development. Two key questions are evaluated. 1) How has divergence within the Anglo-American model influenced corporate governance reform in South Africa? 2) Can South Africa’s historical closeness to the Anglo-American model be combined with increasing attention to stakeholder issues to produce a hybrid “African model” of corporate governance? Evaluating these questions, the following issues are explored in turn: the contrast between shareholder and stakeholder models; divergence between US and UK approaches to corporate governance as exemplified by Sarbanes-Oxley; locating a South African approach in context of the Anglo-American model; the King reports and an emerging “African” model of corporate governance; and the role of international and domestic factors in shaping South Africa’s ongoing reform process.