Stewardship Code
Setting the standard for alternative investment through independent thinking and principled investing.
[Principle 1]
An institutional investor, as a fiduciary managing and operating the assets of clients, beneficiaries, and others, must establish and disclose clear policies to faithfully fulfill its fiduciary responsibilities.
In managing entrusted assets, the firm places the fiduciary duty of care above all else and faithfully fulfills its stewardship responsibilities in accordance with applicable laws, agreements, and articles of association.
The firm places the interests of its limited partners first, does not favor or discriminate against any particular investor without reasonable grounds, and continuously reviews and improves its internal policies and procedures to establish a culture of responsible investment.
[Principle 2]
An institutional investor must establish and disclose effective and clear policies on how to address conflicts of interest that actually arise, or may arise, in the course of fulfilling its fiduciary responsibilities.
The firm operates an internal control framework to identify and manage potential conflicts of interest in advance during the investment and management process. We review potential conflicts among limited partners, portfolio companies, employees, and other funds we manage, and where a conflict arises or is likely to arise, we share the relevant facts in a timely manner and take reasonable measures to protect investors' interests.
[Principle 3]
An institutional investor must periodically monitor its portfolio companies to preserve and enhance the value of its investment assets by improving the medium- to long-term value of those companies.
The firm conducts regular monitoring and post-investment management to enhance the medium- to long-term value of its portfolio companies. We review not only financial performance but also non-financial factors such as management and market conditions, and where necessary, we undertake active value-enhancement activities including engagement with management, network support, and follow-on investment review.
[Principle 4]
An institutional investor should aim to build consensus with its portfolio companies but, where necessary, must establish internal guidelines on the timing, procedures, and methods of activities for fulfilling its fiduciary responsibilities.
The firm aims to build consensus with its portfolio companies and regularly monitors them to enhance their value and advance client interests.
In the course of active shareholder engagement, the firm complies with the Capital Markets Act provisions prohibiting the use of material non-public information, and will not use internal information that materially affects corporate value to gain a trading advantage based on an information edge.
[Principle 5]
An institutional investor must establish and disclose a voting policy including guidelines, procedures, and detailed criteria for the faithful exercise of voting rights, and must disclose the specific details of and reasons for its voting to allow assessment of its appropriateness.
The firm regards voting rights as an important means of protecting investors' long-term interests and enhancing corporate value. When exercising voting rights, we review agenda items based on thorough information gathering and analysis, and make decisions independently and responsibly in the interest of our investors. Key voting records are documented and managed in accordance with the relevant procedures.
[Principle 6]
An institutional investor must periodically report to its clients and beneficiaries on its exercise of voting rights and its activities in fulfilling fiduciary responsibilities.
The firm preserves records of its fiduciary activities, including the status and post-investment management of portfolio companies and its voting records, and faithfully fulfills its reporting obligations to investors as set out in each fund's agreement and articles of association. Upon investor request, we provide monthly, quarterly, and semi-annual reports on a case-by-case basis via electronic communication or in writing, and strive to provide transparent and accurate information to enable sound investment decisions.
[Principle 7]
An institutional investor must possess the capabilities and expertise necessary to actively and effectively fulfill its fiduciary responsibilities.
The firm is composed of professionals with diverse experience and a proven track record across investment and industry, and supports participation in external training programs and industry seminars to strengthen capabilities and enhance expertise.