The power of shareholders over boards and managements can be measured in direct proportion to the noise they make. In other words, the more power they exercise, the less they shout in public to make their views and influence felt.

A recent study by European Corporate Governance Institute experts confirms this thesis and shows how hedge funds and other activist shareholders in the UK are far quieter than their US and continental European counterparts.

Shareholder activism has been particularly effective in the UK without causing all the public cacophony found in the US or some European countries because of the "nuclear deterrent" available to shareholders. Simply put, UK shareholders can call extraordinary meetings with 10 per cent of the voting share capital and put forward propositions to remove any and all directors if more than 50 per cent of votes cast favour the resolution.

With activist funds often able to muster enough votes to topple the board, directors and shareholders have tended to resolve their differences in private. The ECGI study focused on the Hermes UK fund and found that it had succeeded in securing its desired outcomes in the majority of cases. In most cases, the fund's engagement with the companies was conducted through behind the scene contacts with management, board members and other shareholders and far less at public shareholder meetings or other public channels.

This is in sharp contrast to the noise activist shareholders must make in the US where state of Delaware law and the might of corporate boards traditionally favour incumbent management. The same applies to continental Europe where the showdown at Stork in the Netherlands has shown the extremes activist funds will go to in their effort to press public and political opinion. Since the system is stacked against them, the only way to force change is by trying to secure the necessary political and government support.

The same applies to other European countries where big shareholding blocs, relationships and crony networks can still be put in place to frustrate activists. With hedge funds and other activist shareholders continuing to raise their voices - and the continuing debate about the value or shortcomings of shareholder activism - it is no surprise much of corporate Europe is now closing ranks to keep out the troublemakers.