Basic Policy on Japan’s Stewardship Code

JAMP Fund Management Co., Ltd. (the “Company”) is an asset management company entrusted by clients and beneficiaries to manage their assets. As a so-called “Fund Management Company (FMC),” the Company delegates investment management to other discretionary investment managers or manages assets based on advice from investment advisory firms.

Our objective is to expand the medium- to long-term investment returns of our clients and beneficiaries by carefully selecting such external managers, adopting their investment strategies, and providing them to our clients. To fulfill our stewardship responsibilities as an institutional investor—namely, to encourage investee companies to enhance corporate value and achieve sustainable growth through constructive, purposeful dialogue (engagement) grounded in a deep understanding of the companies and their business environments, as well as consideration of sustainability (including ESG factors) aligned with investment strategies—we have established this Basic Policy on Japan’s Stewardship Code, based on the Principles for Responsible Institutional Investors (Japan’s Stewardship Code), as revised in March 2020.

Principle 1 Institutional investors should have a clear policy for fulfilling their stewardship responsibilities and publicly disclose it.

We believe that constructive, purposeful dialogue (engagement) with investee companies—grounded in a deep understanding of those companies and their business environments—is essential to enhancing their corporate value and sustainable growth, which in turn is critical to increasing the medium- to long-term investment returns of our clients and beneficiaries. In selecting external managers, we emphasize their initiatives to enhance investee corporate value, including the exercise of voting rights, thereby fulfilling our stewardship responsibilities as an institutional investor.

Principle 2 Institutional investors should have a clear policy on how to manage conflicts of interest in fulfilling their stewardship responsibilities and publicly disclose it.

We place the interests of our clients and beneficiaries first and manage potential conflicts of interest appropriately. To this end, we have established a Conflict of Interest Management Policy, designed to prevent transactions that may unjustly harm client and beneficiary interests. This policy is publicly disclosed on our website.

Principle 3 Institutional investors should appropriately monitor the status of investee companies to fulfill their stewardship responsibilities for the sustainable growth of those companies.

We recognize that accurately understanding the status of investee companies is a prerequisite for effective engagement. Accordingly, we monitor our external managers to ensure that they continuously and accurately assess investee companies.

Principle 4 Institutional investors should engage in constructive dialogue with investee companies to share awareness and work together to resolve issues.

In selecting delegated managers (or outsourced managers), our company prioritizes constructive engagement aimed at enhancing the corporate value and capital efficiency of investee companies, and promoting their sustainable growth from a medium-to-long-term perspective.

We strive to maintain dialogue with investee companies, recognizing the importance of explaining our holdings, collaborating with other institutional investors, and ensuring fair treatment among shareholders; furthermore, we monitor our delegated managers to ensure they effectively engage with investee companies to share concerns and actively propose solutions to foster improvement.

Principle 5 Institutional investors should have a clear policy on the exercise of voting rights and the public disclosure of such results. The policy for exercising voting rights should not be merely a formal judgment standard but should be carefully designed to contribute to the sustainable growth of investee companies.

We confirm, for each investment strategy, that external managers disclose their basic views and policies on voting and that they exercise voting rights appropriately. As for our own stance, decision-making process, and governance framework regarding proxy voting instructions, these are defined in our Policy on Proxy Voting Instructions, which is disclosed on our website.

Principle 6 Institutional investors should regularly report to clients and beneficiaries on how they fulfill their stewardship responsibilities, including their voting.

We require our external managers to have a clear policy on proxy voting in order to fulfill their stewardship responsibilities, and that such policies be designed to contribute to the sustainable growth of investee companies.
We disclose, as appropriate on our website, the status and results of proxy voting carried out in line with those policies.

Principle 7 To appropriately engage in dialogue with investee companies and make proper judgments in fulfilling their stewardship responsibilities, institutional investors should have in-depth knowledge of investee companies and their business environments, as well as the capability to appropriately consider sustainability consistent with their investment strategies.

Our investment professionals strive to assess whether external managers possess the necessary expertise to engage effectively with investee companies—namely, whether they have the ability to make informed judgments based on a deep understanding of investee companies and their business environments, and on consideration of sustainability consistent with their investment strategies.

We monitor whether external managers maintain sufficient personnel and organizational resources to conduct effective engagement, and through ongoing dialogue with them, we confirm that stewardship responsibilities are being properly fulfilled. In doing so, we aim to contribute to the expansion of medium- to long-term investment returns for our clients and beneficiaries.

Principle 8 Investment service providers should seek to offer appropriate services to institutional investors in the fulfillment of their stewardship responsibilities, thereby contributing to the enhancement of the functions of the entire investment chain.

As our company is not an investment service provider to institutional investors, this Principle does not apply to us.
Nevertheless, we agree with the spirit of the Principle that service providers should seek to contribute to the enhancement of the functions of the entire investment chain as institutional investors fulfill their stewardship responsibilities.