The Directors’ Duty of Loyalty in the German Corporate Law

The article observes the specific duty of loyalty of directors, formed in German corporate law under the influence of Anglo-American approaches. The duty is inseparably linked to the principle of good faith, but has a more specific content. The author analyzes certain elements of the duty of loyalty arising from the noconflict rule of a director and compares them with the approaches of common law jurisdictions. It is noted that Russian corporate law operates with similar ideas, but does not decide to borrow some provisions of the concept.