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It is commonly accepted that the structure of ownership in the US and the UK is widely dispersed while in other countries the situation is one of concentrated ownership. This picture is, however, somewhat exaggerated. The UK is rather more similar to Europe than to the US. In addition, the UK's institutional investors make a relation with the company which is differentiated with the US one. The UK's institutional investors are not reluctant investors or active owners but relationship investors. And this paper reviews the recent changes of the German variant of the stakeholder system. On the level of institutions, the stakeholder system is not being replaced by a shareholder system. Rather, an augmented stakeholder system is emerging through the inclusion of institutional investors in the old stakeholder coalition of interests. On the level of practice, negotiated shareholder value is being adopted in Germany. This German variant of shareholder value is distinct from the US practice because major changes implementing shareholder value must be negotiated within the augmented stakeholder coalition.


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institutional investor, stakeholder, relationship investor, corporate governance, augmented stakeholder system