PART 1: LAY THE FOUNDATION FOR SUCCESS
Chapter 2. What’s Different For the ACCValue Challenge
2 A. What do we mean by “Europe”?
For this ACC Value Challenge guide, when we say Europe, we mean a region made up of
many countries, with a range of governmental structures, legal systems, languages and cultures. We
do not suggest that Europe is a federation of nation states where you will be able to implement your
value-building activities in a uniform way. Europe is indeed a regional market with many significant
distinctions in culture, politics and government systems, all of which have an effect on the law.
Europe is made up of a number of countries that follow civil law and other countries
that follow common law. Civil law countries include: France, Benelux countries, Italy, Romania,
Spain, Germany, Austria, Switzerland, Estonia, Latvia, Czech Republics, Slovenia, Slovakia, Greece,
Portugal, Turkey, Denmark, Norway, Sweden, Finland and Iceland (Scandinavian civil law). The
common law countries in Europe are England, Wales and most of Ireland. Scotland has a mixed law
system of both civil and common law.
In the European Union, the Court of Justice takes a mixed approach, using civil law (based
on the treaties) while emphasizing the importance of case law.
In the European Union, part of the legal regime is homogenous, in that certain laws are the
same in every EU member state. Another part of the EU legal regime is harmonized through an EU
directive allowing each country to (broadly) interpret and enforce it as it wishes. The rest of the law is
independent by member state.
There is also the European Economic Area, or EEA, which includes the EU countries plus
Norway and Switzerland. In the EEA, there is a harmonized legal regime with the EU (such as
Among the European Union’s 27 countries, 15 have the Euro as the currency, and now they
are establishing a banking union.
The judicial systems are different from one country to the next, with some viewed as being
independant and efficient and others as being influenced by politics and business interests. For
example, courts in England and Wales are considered more independent and not influenced by
politics or other interests, while courts in Russia are viewed as less independent, with politics and
other interests considered by many to influence court decisions.