About stewardship activities

■Basic concept

As an asset management company, we consider it our top priority to fulfill our fiduciary responsibilities (duty of loyalty and duty of care) by striving to achieve investment objectives in line with the basic policies set forth in the terms and conditions of each financial product.

In order to achieve this goal, it is necessary not only to select appropriate investment assets, such as stocks and bonds, but also to improve the medium- to long-term value and sustainability of the companies and organizations (hereinafter referred to as “companies, etc.") that issue them. At the same time, maintaining the sustainability of society is a prerequisite.

Through our stewardship activities, we aim to contribute to the enhancement of medium- to long-term value and sustainability of companies, etc., thereby fulfilling our fiduciary responsibilities in asset management and our social responsibilities as a corporate entity.

■Structure of activities

From the perspective of separating management and Investments, we have established a Stewardship Committee within the Investments Division, which is chaired by the Chief Investment Officer (CIO) and composed of personnel from the Investments Division who are involved in stewardship activities. The committee establishes policies for stewardship activities, and under its oversight, corporate research analysts, fund managers, and the stewardship section of the Responsible Investment Department carry out activities systematically.

In addition, the "Stewardship Supervisory Committee" (hereinafter referred to as the "Supervisory Committee"), which consists of outside board directors and the officer in charge of legal compliance who is responsible for managing conflicts of interest, supervises the management of conflicts of interest in stewardship activities, reports to the Board of Directors, and makes recommendations for improvement regarding conflicts of interest as necessary.

The Supervisory Committee ensures independence from management and execution and fulfills a check function by having the chairperson of the Stewardship Committee and at least half of its members be outside board directors.

Organization

Organization

Activity policy

We conduct stewardship activities based on our fundamental approach regarding them.

ESG

  • Together with beneficiaries and companies, etc., in playing a part in the investment chain, we place importance on ESG elements.
  • We have established an ESG Investment Policy that reflects our approach to ESG and extracts important matters (materialities). Under this policy, we conduct stewardship activities to contribute to maintaining and improving the sustainability of both the companies, etc. that we invest in, and of the society itself.

Constructive dialogue (Engagement)

  • Through constructive dialogue, we strive to accurately grasp the situation of companies, etc. and share awareness with them. In addition, we also aim to contribute to improving their medium-to-long-term value and sustainability.
  • We have established a Policy for Constructive Dialogue with Companies, Etc., and actively engage in dialogue under it. This policy summarizes our perspective of wanting to focus on deepening our dialogue with companies, etc. regarding their general situations, including the non-financial aspects as well as the financial ones.

Proxy Voting

  • In exercising our voting rights, we aim to improve the medium-to-long-term value and sustainability of companies, etc., and to that end, we also take into consideration the interests of minority shareholders.
  • We have established a Policy on Exercising Voting Rights to codify our basic approach and specific standards for deciding whether and how to vote, and exercise our voting rights appropriately under it.

Regarding the acceptance of Japan's Stewardship Code

We supports the "Principles for Responsible Institutional Investors (Japan's Stewardship Code)" (hereinafter referred to as the "Code"), published in February 2014, and announced our acceptance of the Code in May 2014.

Principle 1

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

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We have established the "Basic Policy on Stewardship Activities," based on which we have developed and published various policies on our website, including:
・"ESG Investment Policy" including considerations of sustainability
・"Policy for Constructive Dialogue with Companies, etc.," which specifies constructive and purposeful dialogue with investee companies
・"Policy on the Exercise of Voting Rights," which specifies the exercise of voting rights

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.

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To fulfill our fiduciary responsibilities, we have established the "Policy on Customer-First Business Operations" to prioritize the interests of our clients. We have also developed the "Policy on Conflict of Interest Management" to prevent any unjustified harm to our clients' interests.

In conducting stewardship activities, we have established a "Stewardship Committee" within the Asset Management Division to ensure a clear separation between business management and asset management. The Stewardship Committe, which is led by the Chief Investment Officer (CIO) and consists of relevant individuals from the Asset Management Division involved in stewardship activities, sets the policies associated with stewardship activities.
In addition, the "Stewardship Supervisory Committee" (hereinafter referred to as the "Supervisory Committee"), which consists of outside board directors and legal compliance officers responsible for conflict of interest management, supervises overall stewardship activities, reports to the Board of Directors, and makes recommendations for improving stewardship activities as necessary. To ensure independence from management and execution and perform its check function, the Supervisory Committee requires at least half of its members, including the chairperson, to be outside board directors.

Regarding the exercise of voting rights, we manage the exercise of voting rights toward companies with which we currently have capital relationships (affiliates of Daiwa Securities Group Inc. Main Office) and companies with which we have business relationships (distributors of our company's investment trusts and their parent companies), and monitor specific companies where conflicts of interest may arise.

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.

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We have traditionally regarded research on companies as one of the core operations of asset management companies. Centered around our corporate research analysts, we utilize both internal and external information networks to gather information continuously and broadly, striving to accurately understand the circumstances of companies and other entities.

In addition, the "Policy for Constructive Dialogue with Companies, etc." stipulates important items to focus on in dialogue with companies and other entities. Our corporate research analysts, fund managers, and corporate governance personnel engage in dialogue from various standpoints with these companies. We strive to internally share insights gained through dialogue and promptly identify any matters that may pose a risk of impairing corporate value.

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.

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Based on the "Basic Policy on Stewardship Activities," we have established the "Policy for Constructive Dialogue with Companies, etc."

Corporate research analysts, fund managers, and corporate governance personnel engage in dialogue based on the "Policy for Constructive Dialogue with Companies, etc.," striving to share recognition with companies to enhance their mid- to long-term value and sustainability.

Basically, we engage in dialogue with companies independently, regardless of whether it relates to active or passive management. We also consider collaborating with other institutional investors as "collaborative engagement."

Based on the "Policy for Constructive Dialogue with Companies, etc.," we do not accept any undisclosed material information (material facts) from companies during dialogue.

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.

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Based on the "Basic Policy on Stewardship Activities," we have established the "Policy on the Exercise of Voting Rights."

We believe that enhancing the predictability of our voting rights exercise and ensuring that companies understand the reasons for our support or opposition contribute to constructive dialogue with those companies. For this reason, we disclose detailed criteria for our votes in support or opposition. Additionally, we engage in dialogue with companies as necessary to determine our support or opposition. For proposals where our voting decisions differ from our support or opposition criteria, or where individual judgments are made according to our policy, we provide the reasons for those decisions when disclosing the results of our voting rights exercise. We will continue to strive to clearly disclose reasons for our proposals which we determine require such disclosure.

For specific companies where conflicts of interest may arise, we will exercise our voting rights based on the "Policy on the Exercise of Voting Rights." For proposals requiring individual judgment under this policy, we will apply advice from an external specialized organization (Glass, Lewis & Co., LLC) to exercise our voting rights, thereby ensuring the elimination of conflicts of interest and the neutrality of our voting decisions.

In stock lending transactions, there may be instances where the record date for voting rights is crossed. Even in such cases, we will manage the situation to ensure that valid voting rights are secured in accordance with the nature of our proposals.

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.

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We regularly publish reports that summarize the key content of our stewardship activities.

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.

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From the perspective of separating management, execution and operations, we have established the independent "Stewardship Committee" within the Asset Management Division to oversee the stewardship activities of our company. In addition, the Stewardship Supervisory Committee, more than half of the members of which are outside directors, ensures independence from management and execution while performing a check function over all stewardship activities.

In our stewardship activities, we continuously strive to enhance our capabilities for appropriate dialogue and decision-making by sharing information and insights regarding the financial, non-financial, and sustainability aspects of companies obtained by our corporate research analysts, fund managers, and corporate governance personnel from their standpoint.

Furthermore, we have set "contribution to a sustainable society" as one of our guiding principles, and we are systematically working to contribute to the sustainable growth of society. We regularly conduct self-assessments of our implementation of the code and publish the results of these assessments through our reports.

Participation in key initiatives

The United Nations Principles for Responsible Investment (PRI) is a global guideline for responsible investment that aims to improve long-term investment outcomes for beneficiaries by encouraging institutional investors to incorporate ESG issues into their investment decision-making processes and shareholding policy decisions. As a member of the Japan Advisory Committee, we support the PRI's activities in Japan.

The Principles for Financial Action for a Sustainable Society (Principles for Financial Action for the 21st Century) were formulated as action guidelines for domestic financial institutions to fulfill their responsibilities and roles in addressing global environmental and social issues and to create a sustainable society.

The Statement on Fiduciary Duty and Climate Change Disclosure is intended to encourage companies to disclose comprehensive and comparable climate change information in their annual reports and other disclosure documents, based on the recognition that climate change will increasingly impact corporate performance and investment performance.

The 30% Club Japan Investor Group is a coalition of asset owners and asset managers aimed at sharing the importance of gender diversity and gender equality at all levels of organizations through stewardship activities such as constructive dialogues with investee companies. The group is participating in a working group to develop best practices in engagement.

The Task Force on Climate-related Financial Disclosures (TCFD) is a task force established by the Financial Stability Board (FSB) in 2015. The TCFD encourages companies to understand the financial impact of climate change in the transition to a low-carbon economy and disclose related information. We expressed our support for the TCFD in December 2020 and also joined the TCFD Consortium (established in Japan in May 2019).

The International Corporate Governance Network (ICGN) is an international initiative established in 1995. Its mission is to build effective corporate governance and foster investor stewardship to promote efficient global markets and sustainable economies. We participate in conferences and other events organized by the ICGN.

Climate Action 100+ is an international engagement initiative launched by investors in 2017. It encourages large companies that emit large amounts of GHG to make improvements through collaborative engagement. We participate as a collaborative investor in collaborative engagements with Japanese companies in the steel and electrical machinery sectors.

The Investor Agenda is an initiative established in 2018 by a group of institutional investors that provides recommendations to institutional investors and national governments to accelerate efforts to address climate change. We signed a statement by global investors in support of holding COP26.

In December 2020, the Net Zero Asset Managers Initiative (NZAMi) was launched as a global initiative among asset management companies aiming to achieve net-zero greenhouse gas emissions by 2050. As of February 2024, more than 315 companies worldwide are participating, with total assets under management reaching $57 trillion, including many Japanese asset management companies. We have supported and participated in this initiative since December 2021.

The Japan Stewardship Initiative (JSI) was established in 2019 to enhance and advance stewardship activities.

Advance was founded on December 1, 2022. This is an institutional investor initiative established to promote corporate initiatives through collaborative engagement focused on "Social" issues, particularly human rights issues among ESG issues. It promotes initiatives to respect human rights through dialogues with companies that have high human rights risks.

The TNFD is an international initiative that aims to develop and provide a framework for disclosing nature-related financial information. When the TNFD was launched in December 2023, we expressed our support for it as an early adopter.

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①Important Notice

This website aims at providing certain information in relation to a Luxembourg Undertakings for Collective Investment in Transferable Securities ("UCITS") managed by Daiwa Asset Management (Singapore) Ltd. ("Daiwa AM Singapore"). The creation, hosting, maintenance and update of this website has been outsourced by Daiwa Global Funds to Daiwa Asset Management Co. Ltd. ("Daiwa AM Tokyo") which has issued and approved the information contained therein. The UCITS products referred to on this website are not distributed by Daiwa AM Tokyo.

The content of this website is dedicated to inform existing investors in the UCITS and is not, and shall not be construed as, an offer or the solicitation of an offer to buy, sell, or distribute the shares UCITS or any securities or financial products in the jurisdictions from which this website is accessed or any other jurisdiction. Also, nothing in this website constitutes accounting, legal, regulatory, tax or other advice in relation to the UCITS or any other securities or financial products Investors should seek independent accounting, legal, regulatory, tax or other advices based on their personal, financial situation and objectives.

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This website provides information about UCITS products, aimed at institutional investors within the meaning of Luxembourg laws and regulations1 and does not constitute investment recommendation or advice. The information contained in this website is further not intended to be distributed or passed on, directly or indirectly, to any other class of persons and no other person should rely or act upon it. In particular, the information provided by this website is not aimed at "retail investor" within the meaning of Luxembourg laws and regulations2.

The information on this website is not made for any person's use in the United States of America. Also, the information is not, and should not be construed as, an offer or solicitation of an offer to buy or sell share of the UCITS or any other securities or financial products to any person in the United States of America.

③Liability

The information contained in this website is aiming at providing general information on the UCITS based upon sources believed to be reliable, but its accuracy, completeness or correctness is not guaranteed, and it does not indicate or guarantee any future performance.
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Daiwa AM Tokyo further makes no warranties, representations or claims of any kind concerning the statements made on this website or on the fact that the information made available on this website is up to date.

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Daiwa Asset Management Co. Ltd 
Website Data Protection Policy

Daiwa Asset Management Co. Ltd (“Daiwa AM Tokyo” or “we”), acting as a data controller, collects personal data to operate effectively and provide you with the best services. This is why we are highly committed to safeguarding your privacy. In accordance with the provisions of the EU Regulation n°2016/679 of 27 April on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data (the “GDPR”) and the law of 1st August 2018 on the organization of the National Commission for Data Protection and the general regime on data protection, as may be amended or replaced (collectively hereinafter the “Data Protection Laws”), we have developed a Data Protection Policy that covers how we may collect, use, share, protect and keep information about you as well as the rights to which you are entitled in this respect.

Please take a moment to familiarize yourself with our privacy practices.

WHICH PERSONAL DATA DO WE USE ABOUT YOU?


We collect the following categories of personal data, which are directly provided by you when you visit our website or when you require further information about our product and/or services:

  • Name
  • Contact details (such as the mail address and the email address)
  • IP address;
  • Localization data;
  • any personal data the processing of which is required for the purpose of fulfilling the services required by you.

It is to be noted that you have choices about the personal data we collect. When you are asked to provide personal data, you may decline. If you choose not to provide personal data that is necessary to provide our services, we may not be able to deliver the services (i.e. giving you the information you asked).

HOW AND WHY DO WE PROCESS YOUR PERSONAL DATA?


Personal Data supplied by you are processed in order to ensure the good functioning of the website and for our legitimate interests. Such Personal Data shall, in particular, be processed for the purposes of:

  1. providing the correct information to you regarding your investment in our Luxembourg’s Fund
  2. internal administration and analysis
  3. the development of the business relationship with you.

Our “legitimate interests” referred to above are:

  • the processing purpose described in points “2.” and “3.”
  • the exercise of our business in accordance with reasonable market standards.

In specific circumstances, we may request your consent to process your personal data:

  • To perform processing for purposes other than the one for which you initially provide us with your data.

WHO DO WE DISCLOSE OR SHARE YOUR PERSONAL DATA WITH?


We may share with and disclose your personal data to:

  • Companies of our group for the above purposes only.

In principle, your personal data is not shared with or disclosed to third parties located outside the European Economic Area. If a transfer of your data is envisaged with an entity that is not located in the European Economic Area and that is not recognized by the European Commission as offering an adequate level of protection, we will take all appropriate safeguards, before the transfer, such as enter into standard protection clauses adopted by the European Commission, in order to protect your personal data adequately.

HOW LONG WE WILL KEEP YOUR PERSONAL INFORMATION?


We will only retain your personal data:

  • For as long as it is necessary for the purpose or purposes for which it was intended to be processed;
  • For as long as required or permitted by law taking into consideration the statutory limitation period.

WHAT ARE YOUR RIGHTS?


We respect your rights to determine how your personal information is used and seek to ensure that you are able to exercise your rights at any time to the extent required by the law and the regulation. These rights include:

  • Right of access to your personal data

    You have the right to ask us for accessing to your personal data that we process and to ask for a copy of such personal data.

  • Right to rectification

    You have the right ask us to update your personal data and to request the rectification of inaccurate personal data.

  • Right to erasure (‘right to be forgotten’) and the right to restriction

    If at any time you decide you do not want us to retain any personal data we collected from you, you may request we delete your data. You may also request the restriction of the processing of your personal data such as where the accuracy of the data is being contested or the processing is unlawful. We will take reasonable measures to comply with your request to the extent required by applicable law and regulation.

  • Right to data portability

    You have the right to have your personal data transmitted directly from us to another controller only when you have asked us to do so and have consented to such sharing, and when technically feasible.

  • Right to object

    You may object to the processing of your personal data on grounds relating to your particular situation and particularly when the processing is based on our legitimate interests.
    You have also the right to object to the processing of your personal data for direct marketing purpose.

  • Right to withdraw your consent

    You have the right to withdraw your consent at any time, when the processing is based on your consent.

  • Right to lodge a complaint with the CNPD (National Commission for Data Protection)

    You have the right to lodge a complaint with the CNPD, where you believe that your data is being processed in a way that does not comply with the applicable law and regulation, by filling in an online complaint form available on the CNPD Website or by letter addressed to Commission Nationale pour la Protection des Données, Service des Réclamations, 1, avenue du Rock'n'Roll, L-4361 Esch-sur-Alzette. When you reside in another EU member state, you have the right to lodge your complaint with your local data protection supervisory authority.

1 Please note that the definition of institutional investor may not be a definition that is provided by the regulator of the home state where this website is being accessed.

2 Please note that the definition of retail investor may not be a definition that is provided by the regulator of the home state where this website is being accessed.

HOW CAN YOU EXERCISE YOUR RIGHTS?


All the above listed rights may be exercised by writing to us at the following address:

GranTokyo North Tower 9-1,
Marunouchi 1-chome, Chiyoda-ku,
Tokyo 100-6753, Japan

CONTACT US

For further information on Daiwa AM Tokyo’s handling of Personal Data, please contact:

customer_relations@daiwa-am.co.jp

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