oa Comparative and International Law Journal of Southern Africa - A comparison between Anglo-American and South African proxy voting provisions

Volume 2, Issue 3
  • ISSN : 0010-4051



The method used in this article is the comparative one. There are many political, economic and legal differences between American, British and South African corporation law. These and other differences will emerge during the course of this article. Some will prove to be relevant, others not. This is due largely to the fact that despite the differences there are also very basic similarities between American, British and South African corporations and the role of proxies in the corporate scheme of things. One of the most important of these similarities, and one which forms the basis of this article, is the necessity to regulate proxy machinery in order to equalize the scales between management and stockholders.

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