Notes:

• US Model (Rules-Based): Characterized by strict statutory laws (Sarbanes-Oxley, Dodd-Frank), heavy litigation, and detailed SEC disclosure requirements. Focuses on compliance and enforceable shareholder rights .
• UK Model (Principles-Based): Uses the “Comply or Explain” approach (UK Corporate Governance Code). Focuses on board culture, long-termism, and flexibility.
• EU Model: Driven by directives like the Shareholder Rights Directive (SRD II) and CSRD, emphasizing sustainability, employee representation, and binding shareholder votes on pay .
• Emerging Markets: Often blend local customs with international standards, facing challenges in enforcing minority rights and managing State-Owned Enterprises (SOEs) .