Principle 1

Institutional investors should establish and disclose clear policies to faithfully fulfill their fiduciary responsibilities as custodians managing and operating others' assets, such as those of clients and beneficiaries.
 
The Company, established in 2018, operates primarily as a collective investment business in accordance with the "Financial Investment Services and Capital Markets Act" (hereinafter referred to as the "Capital Markets Act"). To fulfill our responsibility to pursue medium- to long-term interests for our clients by promoting the growth and value enhancement of investee companies, we actively engage in activities such as diligent voting, monitoring potential issues, engaging in constructive dialogue, and, if necessary, making productive proposals to resolve issues. In doing so, we consider both financial aspects and non-financial ESG factors of investee companies. The Company adheres to processing procedures and guidelines based on the standards for exercising voting rights. Our fiduciary responsibilities are based on the duties of care and loyalty and may vary by type of collective investment vehicle, asset class, and other factors.

Principle 2

Institutional investors should establish and disclose effective and clear policies on how to resolve conflicts of interest that may arise or are likely to arise in the course of fulfilling their fiduciary responsibilities.
 
The Company recognizes that, in fulfilling its fiduciary responsibilities, there may be conflicts of interest with investee companies that could prevent it from fully prioritizing clients' interests. To prevent this, we have established internal control standards that prioritize clients' interests over the interests of the Company, its shareholders, and employees, and ensure that all clients' interests are treated equally. Employees who encounter conflicts of interest or are concerned about potential conflicts in the course of their duties must consult with the compliance officer in advance to prevent any issues with client protection. If issues of conflict of interest requiring discussion arise during the exercise of fiduciary responsibilities, they are handled by the Internal Control Committee.

Principle 3

Institutional investors should regularly monitor investee companies to enhance their medium- to long-term value and preserve and increase the value of investment assets.
 
To proactively address issues and risks related to shareholder and corporate value, the Company monitors both financial and non-financial factors of investee companies. In addition to financial performance, the Company may utilize quantitatively measured ESG information and qualitative analysis materials for investee companies. We regard monitoring as a critical component of investment activities, frequently assessing both financial aspects, such as sustainability, and non-financial aspects, such as business strategy and governance changes. The Company operates a dual regular monitoring system through methods such as quarterly report reviews, audit report/business report reviews, and ad-hoc methods, such as company visits.

Principle 4

Institutional investors should aim to build consensus with investee companies and, if necessary, establish internal guidelines regarding the timing, procedures, and methods of engagement activities to fulfill fiduciary responsibilities.
 
To fulfill fiduciary responsibilities, the Company engages in active stewardship activities based on continuous monitoring and shareholder value enhancement, with the ultimate purpose of promoting client interests and increasing corporate value. This may include written inquiries, information requests, meetings with the board of directors or management, statement submissions, and exercising voting rights. In the course of active shareholder activities, if we obtain undisclosed material information, the Company may classify the relevant financial investment products associated with the investee company as restricted or cautionary for trading. The compliance officer may limit transactions involving such products. If we receive unintended undisclosed material information during fiduciary activities, we will take necessary steps to minimize the impact on the market in accordance with the Capital Markets Act, related laws, internal control regulations, and internal guidelines.  

Principle 5

Institutional investors should establish and disclose a voting policy that includes guidelines, procedures, and specific criteria for diligent voting, and should disclose the specifics and rationale of voting to assess the appropriateness of such activities.
 
In accordance with the Capital Markets Act, the Company has established the “Guidelines for Exercising Voting Rights” to diligently exercise voting rights. The Company conducts in-depth reviews of investee companies and bases decisions on voting in favor, against, or neutral on the results of dialogue and engagement, aiming to enhance the medium- to long-term value of investee companies and promote clients’ interests.
While we may utilize advisory services from proxy advisory firms regarding voting rights, the Company exercises voting rights based on its own responsibility and judgment, which may differ from the recommendations provided by advisory firms.

Principle 6

Institutional investors should regularly report to clients and beneficiaries on voting and fiduciary responsibility activities.
 
The Company records and manages key fiduciary activities, such as voting and engagement activities, and discloses them transparently, including by posting on the Company’s website. However, if disclosing such information negatively impacts shareholder or corporate value, the Company may choose to keep it confidential.

Principle 7

Institutional investors should possess the necessary skills and expertise to actively and effectively fulfill fiduciary responsibilities.
 
The Company has secured dedicated personnel and organizations with the expertise and capabilities necessary to ensure that fiduciary responsibility activities ultimately contribute to shareholder and corporate value. Relevant departments, including the asset management department, collaborate in carrying out fiduciary responsibility activities. To enhance the expertise of fiduciary responsibility activities, the Company continuously strengthens its internal capabilities, such as training related to relevant industries, and may supplement its expertise through active use of external professional institutions. However, even when utilizing external advisory services, the Company clearly remains the primary party responsible for fulfilling fiduciary responsibilities.