The system of employee directors and employee supervisors is a system of employee representation in management that accompanies our country’s corporate governance system and has distinct Chinese characteristics. It is difficult to find foreign laws with a high degree of similarity, so it cannot be claimed that the system of employee directors and employee supervisors is a transplant. Although the mention of employee directors and employee supervisors often traces back to the German model, claiming that our country’s legislation on employee directors and employee supervisors is transplanted from Germany may not be reliable. Therefore, to examine the system of employee directors and employee supervisors from the perspective of foreign laws, two premises need to be clarified: First, our country’s shareholding reform and corporate legislation are the basic background for the emergence of the system of employee directors and employee supervisors. From a century-long perspective, the company was indeed introduced from abroad. Especially as Western companies came into the view of the Chinese people, the corporate system was passively formed under complex historical backgrounds. The corporate legislation that started in the 1990s is no longer a simple and primitive copy, and it is no longer realistic to look for the prototype of our country’s corporate system abroad. Therefore, there are certain details of the company law that are mainly borrowed from a certain country. For example, the independent director system of the company is borrowed more from American legislation and its practice. Second, the entry of employee representatives into the company’s board of directors and board of supervisors is naturally connected with our country’s enterprise democratic management system and has become a corporate tradition and culture. The root-seeking route should be traced back to the early days of the founding of our Party, and Chinese socialist thought comes from socialist countries. This means that from the perspective of worker participation, practices outside the country may not necessarily reflect more worker participation ideas. However, returning to the corporate system, our country’s worker director and worker supervisor system was indeed introduced from abroad over the past few decades. For example, it is clear that the concepts of “directors and supervisors” are transplants, while the original titles such as “factory director” belong to an outdated system.

Employee Directors, Employee Supervisors

章节
发表日期：

2026年

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Haiming Li

摘要

The system of employee directors and employee supervisors is a system of employee representation in management that accompanies our country’s corporate governance system and has distinct Chinese characteristics. It is difficult to find foreign laws with a high degree of similarity, so it cannot be claimed that the system of employee directors and employee supervisors is a transplant. Although the mention of employee directors and employee supervisors often traces back to the German model, claiming that our country’s legislation on employee directors and employee supervisors is transplanted from Germany may not be reliable. Therefore, to examine the system of employee directors and employee supervisors from the perspective of foreign laws, two premises need to be clarified: First, our country’s shareholding reform and corporate legislation are the basic background for the emergence of the system of employee directors and employee supervisors. From a century-long perspective, the company was indeed introduced from abroad. Especially as Western companies came into the view of the Chinese people, the corporate system was passively formed under complex historical backgrounds. The corporate legislation that started in the 1990s is no longer a simple and primitive copy, and it is no longer realistic to look for the prototype of our country’s corporate system abroad. Therefore, there are certain details of the company law that are mainly borrowed from a certain country. For example, the independent director system of the company is borrowed more from American legislation and its practice. Second, the entry of employee representatives into the company’s board of directors and board of supervisors is naturally connected with our country’s enterprise democratic management system and has become a corporate tradition and culture. The root-seeking route should be traced back to the early days of the founding of our Party, and Chinese socialist thought comes from socialist countries. This means that from the perspective of worker participation, practices outside the country may not necessarily reflect more worker participation ideas. However, returning to the corporate system, our country’s worker director and worker supervisor system was indeed introduced from abroad over the past few decades. For example, it is clear that the concepts of “directors and supervisors” are transplants, while the original titles such as “factory director” belong to an outdated system.