ESG INITIATIVES
GOVERNANCE

ESG INITIATIVES

COMPLIANCE

Takara Asset Management Co., Ltd. (hereinafter referred to as “our company”) not only adheres to laws, regulations, and relevant business laws as an asset management company entrusted with asset management but also complies with broader social norms. Within our company, we have established a compliance framework through the functions of the Board of Directors, Compliance Officer, Compliance Committee, Compliance Department, and a consultation desk to ensure compliance.

MEASURES AGAINST CONFLICTS
OF INTEREST TRANSACTIONS

MEASURES AGAINST CONFLICTS OF INTEREST TRANSACTIONS

Our company has established regulations to prevent transactions that would harm the interests of our clients or engage in unnecessary transactions. When conducting transactions with interested parties, we adhere to the regulations set forth in the Financial Instruments and Exchange Act, the Order for Enforcement of the Investment Trust Act, and our internal rules. It is stipulated that the Compliance Committee and the Investment Committee of each fund department thoroughly verify the transaction details.

PREVENTION OF CONFLICTS
OF INTEREST AMONG PRIVATE FUNDS

To ensure fair treatment between private funds and prevent any unfair advantages, our company has established rules regarding the prioritization of considerations when obtaining acquisition information related to assets that may potentially fall under the investment criteria of both private funds. The Compliance Officer monitors compliance with these rules and reports the results of such monitoring to the Compliance Committee and the Board of Directors on a semi-annual basis.

GOVERNANCE

INTERNAL AUDIT

INTERNAL AUDIT

Our company regards internal audit as one of the most important activities in ensuring the autonomous operation of the company. The purpose of internal audit is to contribute to the achievement of our management goals by evaluating whether the operations and activities of each organization are conducted in compliance with various laws and regulations, appropriately and efficiently; discovering and preventing fraud or significant errors; ensuring the proper management of personal information; and verifying and evaluating other necessary matters. Based on these evaluations, internal audit provides necessary advice and recommendations. We fully recognize the importance of conducting internal audit appropriately and allocate sufficient management resources for its implementation.

INTERNAL REPORTING AND
WHISTLEBLOWER PROTECTION MEASURES

Our company has established regulations that explicitly state the proper handling of consultations or reports regarding systematic or individual violations of laws and regulations from employees or others. These regulations prohibit any detrimental treatment of whistleblowers and emphasize the protection of personal information. By promoting early detection and rectification of misconduct and other irregularities, we strengthen our compliance management.