CONVERGENCE IN EUROPEAN GOVERNANCE CODES: THE AUDIT COMMITTEE CONCEPT

In response to corporate failures in many countries both regulatory and professional bodies have widely promoted audit committees. This paper seeks evidence from an examination of the most recent corporate governance codes issued by 20 countries of convergence in corporate governance systems in Europe by examining the extent to which the audit committee concept (with its Anglo-Saxon origin) has been adopted in Europe. The analyses show that there has been a degree of convergence towards an Anglo-Saxon model of corporate governance as the audit committee concept is widely accepted. However, consistent with the literature on the convergence of European corporate governance systems, the recommendations of the governance codes are not consistent in the specification of a number of factors that contribute to their effectiveness – membership, independence, financial expertise, and roles. A further analysis of the changes in the codes in a number of the countries examined over a period of time revealed a gradual move towards the Anglo-Saxon model. In particular, there was evidence of the recent inclusion in the codes of a number of European countries of a number of the recommendations of the Blue Ribbon Committee (1999) and Higgs Report (2003), which envisage a proactive rather than passive role for audit committees