The European Commission’s Green Paper was issued in April 2011 and seeks to address three main issues: the effectiveness of boards; short-termism among shareholders; and the application of “comply or explain”. The NAPF response highlights that the existing EU corporate governance framework is generally adequate, but that existing rules could be strengthened to create more transparent and efficient capital markets. The response also draws attention to a misconception in the Green Paper that shareholders are too passive and are often focused on short-term profits.