Critical and comparative perspectives on employee participation and share ownership

Research on corporate governance has yet to produce a thorough comparative account of how employees are represented across different economic systems. This article seeks to fill that gap by contrasting two principal approaches: employee participation in decision-making and ownership of company shares. The analysis draws on case studies from Germany, the United Kingdom, the United States, and China, and places them alongside the experience of post-socialist countries such as Croatia, Slovenia, and Serbia. The findings highlight how transitional states face particular legal and institutional obstacles that limit meaningful employee influence, even where laws on paper appear progressive. In Southeast Europe especially, legislative reforms have often failed to take root in practice, exposing a persistent gap between policy ambition and implementation. The study concludes by setting out a framework for reform aimed at designing corporate governance arrangements that are both more inclusive and responsive to the realities of transitional economies.