Mutual fund professionals heard this week that stricter corporate governance regulations are being put in place in each of the major markets ? the US, Europe and UK.

But that may be where the similarities end, with each jurisdiction taking a different path in tightening corporate governance regulations ? and not always agreeing with other jurisdictions on what should and should not be put in place ? as corporations across borders grapple with ensuring their business practices are above board, after a spate of scandals in recent years toppled a number of giant companies.

An update on where various markets are on corporate governance standards was given by fund professionals working in each jurisdictions at the annual Globalisation of Mutual Funds conference being held this week at the Fairmont Southampton.

The panel discussion on Monday, ?The Role of Mutual Funds in Corporate Governance? was chaired by Mark Tennant, senior vice president with JP Morgan Investor Services.

The British perspective on corporate governance for the UK mutual funds sector came from Ida Levine, senior counsel and compliance officer for London-based Capital International Limited.

Christian Strenger, an adviser for capital markets, corporate finance and asset management who formerly worked with Deutsche Bank and now sits on the German Government Commission on Corporate Governance, shared what European funds face and the US view was given by William Tartikoff, senior vice president and general counsel of the Calvert Group Ltd., a Maryland-based mutual fund that has a track record of investing in company?s that are socially responsible.

Mr. Tartikoff said newer regulations on US mutual funds have meant greater disclosure with proxy voting policies and the particulars of votes cast including the declaration of any possible conflicts of interest now being made public.

He said making funds let investors know their voting policies and procedures was bringing the process out of the ?closed offices of ... managers? and giving shareholders some say in how shares in the portfolio are voted.

The new disclosure rules for proxy voting and records were put in place in January, 2003 by the US Securities and Exchange Commission (SEC), but effective dates for compliance with various regulations are being phased in through this year.

Mr. Tartikoff said the SEC, in adopting the new rules, understood that ?proxy voting decisions by funds can play an important role in maximising the value of the funds? investments? as well as ensuring that how proxy votes were cast ?to illuminate potential conflicts of interest and discourage voting that is inconsistent with fund shareholders? best interests?.

Lastly, the SEC said the regulations might encourage some oversight of not only the corporate governance of the fund casting the vote but also of issuers held in the portfolio which could ?benefit all investors and not just fund shareholders?.

Ms Levine said that although the goals of corporate governance principles were the same on both sides of the Atlantic (eliminating potential conflicts of interest, transparency, effective financial disclosure to investors and minority protection), the tools and focus had been different.

In the US, Ms Levine said the focus of corporate governance ? culminating in Sarbanes-Oxley ? had been to weed out and guard against accounting irregularities, fraud and financial mismanagement, as seen with Enron, WorldCom and Tyco.

The situation was somewhat different in the UK, where the focus was on limiting the potential for conflicts of interest of public company directors. This has led to a drive for increased transparency from listed companies as well as ensuring boards have independent directors and that remuneration of directors is an independent function, for example by keeping directors from signing off their own pay deals.

Although British companies listed on the London Stock Exchange must all comply with listing rules for public companies, a further set of rules ? the Combined Code on Corporate Governance was extensively updated in July of last year.

That followed the publication of two pivotal reports, the ?Higgs Review? (which called for 50 percent of boards to be independent, a greater role for the chairman of the board, and an independent nominating committee amongst other changes) and the ?Smith Report? ? must also be complied with, or an explanation must be given for not complying.

This ?comply or explain? regime put some of the onus on investors, who are in turn putting pressure on funds to meet the requirements in the corporate governance code.

?So, the UK has a regime which, while not compulsory, is actively monitored by big institutional investors,? she said.

She added that although there was nothing to require institutional investors to disclose proxy votes, some were doing so voluntarily.

Mr. Strenger said that European fund managers were actively complying with ?best? corporate governance practices as defined by various directives including from the OECD (Corporate Governance Principles 2004) and IOSCO, as well as national recommendations country by country.

But just as the US and UK had different areas of focus on corporate governance of mutual funds, so did continental Europe, said Mr. Strenger.

For example, the UK?s focus push on controlling remuneration of boards and executives was less of an issue in Europe, as they are ?not paid enough anyhow?.

But he said there was still work to be done, with a recent trends survey of European funds finding that 67 percent of respondents felt corporate governance standards were improving but varied from country to country with UK fund managers, then Swedish fund managers being the two most active while Spain and Italy were ranked lowest.

Mr. Strenger said shareholders rights varied from country to country, as did views on governance issues. More than 50 percent of the top 30 German companies resisted making certain information public, he said, adding that they were doing ?themselves no favours? as they were putting greater scrutiny on the issue. He said voting policies and proxy committees were also not generally established in Germany yet.

But Mr. Strenger said he was hopeful that a drive for cross-border consistency in corporate governance regulations would be in place within two years.