기업지배구조 코드 운용 현황에 관한 비교 검토- 영국과 일본의 기업지배구조코드를 중심으로 -

In 2018, the Korea Exchange changed the disclosure of corporate governance reports from the voluntary disclosure to a mandatory disclosure. As a comparative legal review in the current situation where phased mandatory disclosure system is being implemented, this paper reviews the structural characteristics of UK and Japanese corporate governance codes by analyzing the current status of their implementations. The paper is to provide specific reference for comparative legal study to verify the regulatory direction and validity of corporate disclosure system in Korea. This paper studies (i) the structure and operation status of the UK corporate governance code and its applications. Specifically, it reviews the implementations of the UK codes by analyzing the report published in 2021 by Grant Thornton. In the same way, the paper studies (ii) the Japanese corporate governance code and its implementations. It reviews the structure and application status of the Japanese code and the white paper on corporate governance published by Tokyo Stock Exchange in June 2021. It also examines (iii) the corporate governance report disclosure system implemented by the Korea Exchange, and (iv) presents some implications to current Korean system in the light of the cases of UK and Japanese corporate governance codes and implementations.