Japan Financial Services Agency Public consultation on draft revisions to their Stewardship Code

We refer to Financial Services Agency’s consultation on proposed revisions to the Japan Stewardship Code. We appreciate the opportunity to provide feedback as FSA revises the Code with the objectives of promoting collective engagement, increasing the transparency of beneficial shareholders and streamlining the code to be more principles-based. These objectives help to deliver FSA’s target outcome of deeper and more effective dialogue between investors and companies. This outcome is a fundamental component of the wider corporate governance reform in Japan, which we fully support.

Norges Bank Investment Management (NBIM) is the investment management division of the Norwegian Central Bank and is responsible for investing the Norwegian Government Pension Fund Global. NBIM is a globally diversified investment manager with JPY273.1 trillion at 31 December 2024, of which JPY17.5 trillion was invested in the shares of 1,436 Japanese listed companies.

As a long-term investor, we consider our returns over time to be dependent on well-functioning, legitimate and efficient markets as well as sustainable economic, environmental and social development. As we own on average 1.5% of all listed companies, we can monitor and engage them to promote long-term value creation and minimise negative effects on the environment and society. Our stewardship activities contribute to the fund's objective of highest possible return with acceptable risk.

As a sovereign wealth fund, NBIM does not sign up to stewardship codes, however we appreciate the critical role of stewardship codes in setting expectations on responsible investment practices that institutional investors should adopt as they fulfil their stewardship responsibilities towards investee companies, clients and beneficiaries. In this spirit, we would like to share our views with FSA.

We thank you for considering our perspective and remain at your disposal for further discussions.

Please find in Annex A our responses to the consultation questions.

Yours sincerely

Carine Smith Ihenacho,
Chief Governance and Compliance Officer

Jeanne Stampe,
Lead Policy Advisor