Disqualification of company directors : a comparative analysis of the law in the UK, Australia, South Africa, the US, and Germany

Présentation de l'éditeur : "This book provides a clear overview of the legal rules relating to directors' disqualification in Australia, Germany, South Africa, the UK and the US, and to highlight the differences in the disqualification regimes of these jurisdictions. The book seeks to determine whether disqualification on application should be developed further as a corporate law and corporate governance tool to ensure that individuals who have a proven record of posing a particular risk to the business community, shareholders and creditors, are indeed disqualified from being directors. The book is unique as it provides a single source where the disqualification regimes of all these jurisdictions are explored and compared. The book will appeal to scholars of corporate law, regulators and policy-makers. The book will also be of particular interest to senior managers and directors to determine precisely what the laws regarding disqualification of company directors are, and what type of behaviour might expose them to potential disqualification." Présentation de l'éditeur : "This book provides a clear overview of the legal rules relating to directors' disqualification in Australia, Germany, South Africa, the UK and the US, and to highlight the differences in the disqualification regimes of these jurisdictions. The book seeks to determine whether disqualification on application should be developed further as a corporate law and corporate governance tool to ensure that individuals who have a proven record of posing a particular risk to the business community, shareholders and creditors, are indeed disqualified from being directors. The book is unique as it provides a single source where the disqualification regimes of all these jurisdictions are explored and compared. The book will appeal to scholars of corporate law, regulators and policy-makers. The book will also be of particular interest to senior managers and directors to determine precisely what the laws regarding disqualification of company directors are, and what type of behaviour might expose them to potential disqualification." "This book provides an ... overview of the legal rules relating to directors' disqualification in Australia, Germany, South Africa, the UK and the US, and to highlight the differences in the disqualification regimes of these jurisdictions. The book seeks to determine whether disqualification on application should be developed further as a corporate law and corporate governance tool to ensure that individuals who have a proven record of posing a particular risk to the business community, shareholders and creditors, are indeed disqualified from being directors. The book is unique as it provides a single source where the disqualification regimes of all these jurisdictions are explored and compared."-- Provided by publisher Analyses, perspectives and jurisdictional overview / Jean Jacques du Plessis and Jeanne Nel de Koker -- The United Kingdom / Andreas Rühmkorf and Jean Jacques du Plessis -- Australia / Tess Blackie and Jean Jacques du Plessis -- South Africa / Neels Kilian, Jean du Plessis, and Jeanne Nel de Koker -- United States / Hannah Marie Farhan and Jeanne Nel de Koker -- Germany / Andreas Rühmkorf Cover 1 Half Title 2 Title Page 4 Copyright Page 5 Table of Contents 6 Table of cases 8 Table of legislation 14 List of tables 32 About the editors and authors 34 Preface 38 1 Analyses, perspectives and jurisdictional overview 40 2 The United Kingdom 71 3 Australia 108 4 South Africa 151 5 The United States 194 6 Germany 212 Index 239 1. Overview, Jean du Plessis and Jeanne Nel de Koker 2. United Kingdom, Andreas Ru hmkorf and Jean du Plessis 3. Australia, Tess Blackie and Jean du Plessis 4. South Africa, Neels Kilian, Jean du Plessis and Jeanne Nel de Koker 5. US, Hannah Marie Farhan and Jeanne Nel de Koker 6. Germany, Andreas Ru hmkorf