【正文】 financial intermediation cannot be assessed immediately. For example, nonperforming loans tend to be discovered in the future not at the time of issuance (Wei 2020). It is clear that, in the Chinese case, the state has allocated to itself the main role in the banking system and, historically speaking at least, this differentiates Chinese corporate governance models from those found in AngloSaxon countries. Officials argue for the merits of this system on the basis that, at China’s current stage of development, markets would not fairly allocate resources and the government has a responsibility for managing the financial system so that development occurs rapidly, but with stability (Zhou 2020). That there are differences between the AngloSaxon and the Chinese models of corporate governance is hardly surprising. The ‘varieties of capitalism’ research tradition has produced numerous case studies demonstrating that there has been little convergence in terms of governance structures or economic policy making over the last 20 years despite extensive financial globalization (Clarke 2020, Nee 2020, Streek and Thelen 2020). Comparative organizational scholars have also produced many studies which show that firms adopt various modes of economic action and organizational forms which are largely based on the institutional structures embedded in their nationstate base (Boisot and Child 1998, Guillen 2020, Redding and Witt 2020). Moreover, Chinese thinking about international norms has been shown to vary across time, sector and issue (Wang 2020). In a study of policy documents and media mentary, Wang suggests that Chinese officials remain open to international norms in the economic and technical realms but less so to those governing other issues, especially political and military matters. Wang argues that it seems likely that China will abide by prevailing international economic and technical norms and will bee an increasingly congruent and cooperative economic partner in the global arena. It is probably fair to say that, at the official level, the reform of China’s banking system was partly influenced by the policy discourse ‘link up with the international track’ (yu guoji jieguei) whereby China’s banks were encouraged to move towards 422 J. Nolan international standards both in terms of product innovation, accounting procedures and corporate governance mechanisms (Cousin 2020, Calomiris 2020, Wang 2020). This publiclystated objective, does, however, raise interesting questions as to the practicalities of transferring corporate governance practices across culture, and, following Aguiler and Jackson (2020), this study will argue that multiple institutions will interact to influence the perceived legitimacy and utility of western corporate governance practices in the Chinese context. Although there is some discussion over just quite what an ‘institution’ is, it is probably fair to say that most would agree that an institution enpasses both the informal beliefs and behaviours of a given society and the formal organizations of the state that govern those beliefs and behaviours (Nee 2020). Within this general framework, it is possible to differentiate further between functionalist or ‘rational choice’ theories and path dependency or ‘varieties of capitalism’ approaches to institutional change (with the latter sometimes referred to as ‘neoinstitutionalism’). Each approach rests on different behavioural assumptions (principally the degree to which rational action is limited and shaped by context), and fo