Policy for Fulfilling Stewardship Responsibilities ｜Governance | Sustainability

Basic policy

The Company is implementing a contract-type defined-benefit corporate pension plan, and as the asset owner of corporate pension asset management, we announce that we accept the principles of the "responsible institutional investor", Japan's Stewardship Code.

Since our corporate pension fund does not directly hold shares, etc. and we outsource asset management to investment managers, we accept the "Japan's Stewardship Code," and will fulfill our stewardship responsibilities as an asset owner by requesting stewardship activities following the code.

Correspondence to each principle of “Japan’s Stewardship Code"

Principle 1. Institutional investors should have a clear policy on how they fulfill their stewardship responsibilities and publicly disclose it.

Since the Company outsources the management of corporate pension assets to investment managers, we request them to engage in effective stewardship activities based on a deep understanding of the investee companies and their business environment, as well as sustainability considerations in line with its investment strategy, and report the activities' results. The Company monitors the adequacy of the stewardship activities of the investment manager as well.

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.

We recognize that the management of corporate pension assets outsourcing to investment managers may cause conflicts of interest when the outsourced investment managers exercise their voting responsibilities to us.

However, we recognize the importance of constructive dialogue with shareholders and the exercise of voting responsibilities, to maintain our own healthy and sustainable growth and enhance corporate value over the medium to long term. Hence we respect the investment managers to exercise the voting responsibilities to fulfill the stewardship responsibilities.

The Company has also established the Pension Advisory Committee, which is composed of in-house experts, as an advisory body regarding the proper operation and asset management of corporate pensions.

In addition to our conflicts of interest, we formulate and publish clear policies regarding conflicts of interest that should be managed to fulfill stewardship responsibilities and request that such investment institutions comply with them.

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.

Since the Company outsources the management of corporate pension assets to investment managers, we request them to monitor appropriately for the fulfillment of their stewardship responsibilities toward sustainable growth.

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.

Since the Company outsources the management of corporate pension assets to investment managers, we request them to seek to arrive at an understanding in common and work to solve problems through constructive and "purposeful dialogue" with investee companies.

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.

Since the Company outsources the management of corporate pension assets to investment managers and is not in a position to exercise the voting responsibilities of investee companies, we request that the investment managers establishment of a policy for exercising voting rights and publicizing the results of the exercising and the disclosure of the result of exercising to fulfill the stewardship responsibilities of the investment trustees.

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

Since the Company outsources the management of corporate pension assets to investment managers, and we are in a position to fulfill stewardship responsibilities through the investment managers of the contractors, we request a report on the implementation status and report the results to the beneficiaries of corporate pensions at least once a year.

Principle 7. To contribute positively to the sustainable growth of investee companies, institutional investors should develop skills and resources needed to appropriately engage with the companies and to make proper judgments in fulfilling their stewardship activities based on in-depth knowledge of the investee companies and their business environment and consideration of sustainability consistent with their investment management strategies.

Since the Company outsources the management of corporate pension assets to investment managers, we request the investment managers have the appropriate skill to fulfill their stewardship activities.

In addition, the Company will endeavor to have the ability to understand and evaluate the stewardship activities of the investment managers.