Setting the scene
One of the starting points in company law is the one share
one vote principle, meaning that each share entitles to one
vote. However, issuing classes of shares with different voting and
financial rights is permitted in many jurisdictions. The Nordic
countries have a long-established corporate practice of using
different classes of shares forming control-oriented corporate
governance systems in limited liability companies. Having a
'blockholder', a single shareholder or a cohesive alliance
of shareholders, who own a major fraction of the voting rights in
order to hold a controlling position in the company, has
traditionally been quite common in the Nordic countries. At the
same time, corporate practice in the UK and the United States have
had more of an 'arms-length' system of ownership and
control due to widely dispersed share ownership, which is common in
these jurisdictions. During the past few years, the Nordic
control-oriented corporate