4.7.1 Introduction

The underlying chapter contains the theoretical legal comparative analysis within research part II on the comply or explain principle in practice, since per EU country investigated (Belgium, Italy, Germany, the Netherlands and the UK) the specifics of the comply or explain principle, corporate governance system and regulation are provided by the answering of eight key questions. This then answers the specific research question of this chapter: What is, based upon comparative legal analysis, the layout of the comply or explain principle as embedded in the corporate governance systems of five Member States and does a common understanding ofthe principle s scope and its most effective form currently exist within the EU?

In this section a summary of the key findings of the above comparative legal analysis is provided (section 4.7.2). Section 4.7.3 summarises the results of the optimum framework for the countries under research and specifies the framework further. Section 4.7.4 links the cultural dimensions, as elaborated upon in chapter 3, to the layout of the comply or explain principle as embedded in the corporate governance systems of the five Member States. The conclusions regarding the specific research question of this chapter are provided in section 4.7.5.