Comparative Corporate Governance: A Cross-Jurisdictional Analysis of Shareholder Rights in the United States, United Kingdom, and European Union

Abstract

Corporate governance frameworks worldwide grapple with balancing shareholder primacy against broader stakeholder interests amid globalization, technological disruption, and sustainability imperatives. This comprehensive article conducts a doctrinal and empirical comparison of shareholder rights in the United States (US), United Kingdom (UK), and European Union (EU), scrutinizing proxy voting mechanisms, fiduciary duties, minority protections, and enforcement regimes. Drawing on legal texts, case law, regulatory evolutions through 2025—including President Trump's deregulation initiatives—and quantitative data from 1,000+ listed firms, it identifies key divergences: US litigation dominance, UK stewardship flexibility, and EU stakeholder mandates. The analysis proposes a hybrid model for convergence, incorporating digital tools and ESG harmonization to bolster investor confidence and corporate resilience. Empirical regressions affirm stewardship's superior total shareholder return (TSR) correlation.