The system in Germany is different in that it names a particular set of stakeholders, namely workers, and gives them a formal place in governance controls. To m

The system in Germany is different in that it names a particular set of stakeholders, namely workers, and gives them a formal place in governance controls. To my knowledge, German managers do not have to take into account the objectives of suppliers, the local economy, or society at large in their decision making. While it's similar, it actually addresses the first point I made, as compared with the California law under discussion. German companies have much more concentrated share ownership, which gives them an advantage for corporate governance that perhaps makes scandals less likely. Also, they are a product of the German culture which is very different from American culture.