In an article published in the Harvard Business Review, JC de Swaan from Princeton University, contrasts the roles of activist hedge funds in the U.S. and in Japan. De Swaan writes " In the U.S., CEOs live in fear of activist hedge funds, and politicians worry about their effects on workers. But the case for shareholder activism is perhaps best seen in Japan, where the corporate sector tends to be structurally skewed in favor of employees, at the expense of shareholders and the economy. In Japan several factors combine to help insulate managers from outside influence, including cross-holdings where the company owns shares in a partner firm, docile boards mostly composed of company executives, and a court system historically biased against investment funds. In Japan the worry lately has not been about too much shareholder activism but about too little. Remarkably, Prime Minister Shinzo Abe has embraced shareholder activism, in a bid to encourage the adoption of his corporate governance reforms, a central part of his economic policy platform."