About Stewardship Code

“Company”) hereby declares that the Company endorses and adopts the Principles for Responsible Institutional Investors (also known as Japan’s Stewardship Code).
For details of Japan’s Stewardship Code, please refer to the website of the Financial Services Agency.

Our policies and views on Japan’s Stewardship Code are as shown below:

Principle 1.

Institutional investors should have a clear policy on how they fulfill their stewardship responsibilities, and publicly disclose it.

The Company bears the responsibility for investing funds deposited by investors (equity investors in a fund) in companies via the fund and increase their returns.
We principally make hands-on investments in both listed and unlisted companies with no restrictions in investments in terms of their industry sectors and scale. Specifically, through such hands-on investments, we will endeavor to increase the corporate value of investee companies and contribute not only to the investee companies, their executives and employees, and investors but also to society by flexibly designing investment strategies and working closely with these companies, while maintaining full communication with them.

Principle 2.

Institutional investors should have a clear policy on how they manage conflicts of interest in fulfilling their stewardship responsibilities and publicly disclose it.

In the event there is a risk of conflicts of interest, the Company will strive not to damage the interests of investors by complying with investment partnership agreements, related laws and regulations, and related internal rules.

Principle 3.

Institutional investors should monitor investee companies so that they can appropriately fulfill their stewardship responsibilities with an orientation towards the sustainable growth of the companies.

In the process of selecting an investee company prior to actually making investments, we make sure that we fully understand the status of the investee company, its risks, and its growth potential in the future through multiple interviews with its key management members, hearings from industry experts, and legal and financial due diligence with the help of outside professionals.
After making investments, we build trust and share information with the company by attending meetings, including management meetings and board meetings, and through dialogues with management members, and gain an understanding of its operating performance, governance, and risk management and other systems by periodically obtaining financial information and other materials.
In addition, we pay meticulous care to the handling of information when we invest in listed companies, so as to prevent the trading of the company’s shares by those who hold insider information.

Principle 4.

Institutional investors should seek to arrive at an understanding in common with investee companies and work to solve problems through constructive engagement with investee companies.

The Company strives to share recognition with investee companies, eliminate potential risks, and improve issues by actively engaging in dialogues with related parties of investee companies, including top management members and those in managerial positions, and deepening mutual understanding with them.

Principle 5.

Institutional investors should have a clear policy on voting and disclosure of voting activity. The policy on voting should not be comprised only of a mechanical checklist; it should be designed to contribute to the sustainable growth of investee companies.

We refrain from disclosing the results of voting as most of our investee companies are unlisted companies.
We exercise our voting rights on respective agendas of an investee company by fully taking into account such factors as how the company is operated, its growth potential, and the interests of investors, and in accordance with the rules set forth within the Company.

Principle 6.

Institutional investors in principle should report periodically on how they have fulfilled their stewardship responsibilities, including their voting responsibilities, to their clients and beneficiaries.

We will report how we have fulfilled stewardship responsibilities to investors thorough periodical reports or at general meetings of partners.

Principle 7.

To contribute positively to the sustainable growth of investee companies, institutional investors should have in-depth knowledge of the investee companies and their business environment and skills and resources needed to appropriately engage with the companies and make proper judgments in fulfilling their stewardship activities.

We have put in place a system needed to support investee companies and engage in stewardship activities.
On top of the above, to improve the ability of our personnel in charge of investment to provide high-quality support and appropriately fulfill our stewardship activities, we will build up a track record of investments, proactively share information about precedent success cases and other information that may be disclosed, and keep honing our skills.