KEY FEATURES OF CORPORATE GOVERNANCE IN EAST ASIAN ‎APPROACH AND IN IRANIAN LAW: A COMPARATIVE STUDY

Corporate Governance is one of the most challenging issues in the world of law, which is due to its special role in joint stock companies, especially  those presenting their stocks in the stock exchange market. Among the approaches to corporate governance developed in the capital markets of developed countries, three are identified as the Anglo-American Approach, the Continental European Approach, and the East Asian Approach. (Baker & Anderson, 2010: 7) The first two approaches, more commonly adopted throughout the world, have already been the subject of a few studies in Iran, but the third has been disregarded so far. Given that there is no specific binding rules about the corporate governance in Iranian law, the study of the East Asian Approach, which is different in most of its features from the one exercised in Iran, can help to design a specific model of corporate governance in this country. Comparing the rules of Iranian Joint Stock Companies with the East Asian Approach will show that the Iranian legal system, while having employed more vigorous strategies than the latter approach towards financial transparency, is less advantageous at least in terms of managerial balance and sources of financing, and it is necessary that the Iranian Legislature takes effective steps forward in these respects based on a localistic insight.