Compliance and Risk Management

Decision-making process

The Asset Manager has four committees: the Investment Committee, the Risk Management Committee (the Risk Management Committee acting as advisory board to facilitate decision-making, not a decision-maker), the Compliance Committee and the Compensation Committee in place.
In the course of making a decision regarding our investment policy and standards, operation and management policy and standards, budget and financing, as well as the acquisition, disposal, or operation and management of assets, a proposal will be submitted to the Asset Manager's Board of Directors for approval in accordance with rules of the Board of Directors. Proposals relating to stakeholder transactions of the Asset Manager, must first be approved by the Compliance Committee before they are submitted to the Investment Committee (excluding “Minor Transactions” which is stipulated in the Regulations for Transactions with Stakeholders) . In addition, subsequent to approval by the Board of Directors of the Asset Manager, approval from our board of directors is required prior to a transaction involving the acquisition, disposal or lending of securities or real estate between us and a related party (as defined in Article 201-1 of the Investment Trust Act) of the Asset Manager, except certain of such transactions determined not to have a significant impact on us under the Ordinance for Enforcement of the Investment Trust Act.

The chart below outlines the decision-making process of the Asset Manager

(1)...With regard to matters relating to the acquisition, disposition, operation and management of assets, the approval of the Investment Committee will be obtained based on the Guidelines for the Investment Committee.
(2)...With regard to the investment policy and standards, operation and management policy and standards, budget and financing, etc. for the Investment Corporation, the approval of the Investment Committee and the Board of Directors will be obtained in accordance with the Guidelines for the Investment Committee and the Rules for the Board of Directors.
(3)...With regard to matters relating to transactions with stakeholders stipulated in the Regulations for Transactions with Stakeholders, the approval of the Compliance Committee, the Investment Committee and the Board of Directors will be obtained in accordance with the Regulations for Transactions with Stakeholders, the Guidelines for the Investment Committee and the Rules for the Board of Directors. In the case of Minor Transactions, the approval at the Compliance Committee and the Board of Directors is not required.
(4)...In the case of transactions determined not to have a significant impact on asset of the investment corporation under the Ordinance for Enforcement of the Investment Trust Act, consent of the investment corporation based on the approval by its board of directors is not required.