An analytical overview of the regulation of shareholder activism in the UK and Germany. The book shows how the comparative legal method can be used in the study of the corporate governance systems of different countries. It deals with the regulation of the governance of listed companies within a wide framework that recognises the importance of company law, securities markets law, standards and internal rule-making.

Zusammenfassung
It is fairly easy for a Finnish Jurist to understand German Company law. On the other hand, UK Company law seems very confusing. What is even more confusing is that the UK corporate govemance model is often regarded as one of the best in the World. Clearly German law cannot be as bad as it is often said to be. This books results from these kinds of thoughts and an interest in comparative law, Company law and securities markets law. I wanted to find out whether the functional method would give anything new to say about the regulation of corpo­ rate govemance in Germany and the UK. As I have been lecturing on Company law and corporate govemance myself, I also wanted to write a book that I could use as a textbook in my courses. For this reason, I focused on one of the key questions in corporate govemance: the regula­ tion of shareholder activism.

Inhalt
Comparative Law and Corporate Governance.- The Law of the European Union.- The United Kingdom.- Germany.- Comparison.