Corporate governance frameworks across Southern Africa have undergone significant reform, yet a systematic comparative analysis of their convergence and divergence is lacking. This gap hinders regional integration and investment. This working paper aims to map, compare, and evaluate the dominant corporate governance models within the region. It seeks to identify key institutional drivers and assess their alignment with international standards and local socio-economic contexts. The analysis employs a comparative institutional approach, examining primary legal statutes, regulatory codes, and stock exchange listing requirements. A structured qualitative content analysis was conducted on these documents to identify core principles, enforcement mechanisms, and board structures. A distinct hybrid model, blending Anglo-American shareholder-oriented norms with stakeholder-inclusive elements, is prevalent. Notably, a clear thematic divergence exists regarding board independence, with one major economy mandating a minimum of 40% independent non-executive directors, while others adopt a principles-based 'comply or explain' approach. The region exhibits a coherent but uneven governance ecosystem, where formal regulatory convergence masks significant variation in implementation capacity and enforcement rigour. Policymakers should prioritise harmonising disclosure requirements and strengthening regulatory capacity. Firms are advised to enhance board evaluation processes that address both universal principles and local stakeholder expectations. corporate governance, comparative analysis, institutional theory, Southern Africa, regulatory frameworks, board structure This paper provides the first systematic, region-wide mapping of corporate governance codes, introducing a novel typology for classifying hybrid governance systems in emerging markets.
Merwe et al. (2023) studied this question.