Shareholder wealth maximization is a norm of corporate governance that encourages a firm's board of directors (the board) to implement all major decisions such as compensation policy, new investments, dividend policy, strategic direction and corporate strategy with only the interests of shareholders in mind." There is strong support for the idea that shareholder wealth maximization should be the primary norm underlying the governance of for-profit corporations.' Given this majority view, it should come as no surprise that many practitioners and scholars also consider shareholder wealth maximization to be the objective of corporate law with corporate law's fiduciary duties of care and loyalty being the tools of accountability to enforce this objective