While individual countries have addressed--or are addressing--the issue of transparency and accountability, the lack of unity on the subject may hamper investors' interest in cross-border trading, some panelists noted. Throughout the discussion, the debate seemed to reflect many of the issues raised a few years ago in the US, when Sarbanes-Oxley became the law of the land.

"It's better that we do it ourselves," said Elizabeth Peace, chief executive of the British Property Federation. "We don't want government poking its nose in our business."

But does Sarbanes-Oxley, despite its government origins, offer a model for Europe? Not at those prices, Peace said. "It's jolly expensive, and that's one reason so many REITs have gone private."

Much of the conversation revolved around the need to regulate the unlisted companies, since some form of code exists in the major European countries for listed firms. Most of the panelists believed that the market itself would bring that pressure to bear.

"It's the investor who will go to the specific company and ask, 'Why haven't you implemented this?'," stated EPRA CEO Nicholas van Ommen (EPRA is the European equivalent of Nareit). The only reason for not implementing governance would be local legal restrictions, he added.

Paul Marcuse, CEO of AXA Real Estate Investment Managers, sees the issue as one of maturation. "This is still a relatively immature market," he told the assembled crowd. "But it's a market that's growing rapidly, and this needs to grow with it." It will be key to investor activity, he added: "Investors will discriminate based on these factors."

If the continent as a whole does address a unified code, it will have to do so in relatively small bites, Marcuse argued. "The code should provide basic standards," he pointed out, despite the fact that the industry has so many different levels of investor. "We shouldn't try to address everyone or it will take too long to get anything."

At the end of the day, the need for a unified code, embracing listed and unlisted companies alike, was clear, and it transcends profit. "This is about moral and ethical behavior," van Ommen concluded.