This paper introduces a comparative approach of the fi duciary duty of loyalty in European jurisdictions and examines national regulations and jurisprudential understandings of this duty, which is imported from common law. We will pursue the evolution of interpretations in continental law and analyze recent European studies that extend the scope of loyalty to new areas such as personal data protection or efficient use of natural resourc...

The paper analyzes the jurisprudential recognition of good faith in corporate governance, initially as a condition of the business judgement rule and subsequently as a component of the duty of loyalty. The objective of this paper is not to identify the contours of this duty, rather it will examine different interpretation methods, the most relevant being the identification of good faith as a distinct and selfstanding fiduciary duty in 19...