This text compares the corporate governance structures of the US quoted company and its European equivalent and the role which employees as non-shareholding stakeholders hold within those structures. It focuses on the incidents of ownership normally exercised by stakeholders and raises questions regarding different responses to the issue of mandated labour market regulation on both sides of the Atlantic. The text considers theoretical and practical issues raised in this context.

Irene Lynch-Fannon is Dean of the Faculty of Law and Head of the Department of Law at University College Cork,Ireland.