Policy on Investment Corporation-Oriented Business Conduct
Revised June 30, 2025
Latest initiatives and key performance indicators (KPIs): Updated June 30, 2025
Mitsui Bussan & IDERA Partners Co., Ltd. (hereinafter the “Asset Manager”) has adopted the “Principles for Customer-Oriented Business Conduct” announced by the Financial Services Agency on March 30, 2017 (including amendments enforced thereafter,) and has established the “Policy on Investment Corporation-Oriented Business Conduct” (hereinafter the “Policy”).
The Asset Manager has established the following management philosophy: “As the asset manager of MIRAI Corporation (hereinafter ‘MIRAI’), the Asset Manager shall strive to secure stable earnings for MIRAI and achieve steady growth of its assets under management through continuous investment, with the aim of enhancing unitholder value over the medium to long term.” The Asset Manager has been striving to conduct its business in a manner that is consistent with the interests of MIRAI, and has formulated the policy to further reinforce its commitment. In order to clarify how each policy corresponds to the “Principles for Customer-Oriented Business Conduct” published by the Financial Services Agency, the numbers of Principles 2 to 7 and Supplementary Principles 1 to 5 corresponding to each policy are listed at the end of each policy.
The Asset Manager reviews the policy as necessary and regularly disclose the specific status of initiatives and key performance indicators (KPIs) related to the policy.
Please click here to see the latest initiatives and key performance indicators (KPIs) (Japanese only).
Pursuit of the Investment Corporation’s (Our Customer’s) Best Interests [Principle 2]
As the Asset Manager entrusted with the management of MIRAI’s assets, the Asset Manager maintains a high standard of expertise and professional ethics, and strives to pursue the best interests of MIRAI by utilizing its creativity and ingenuity. The Asset Manager also strives to establish investment corporation-oriented business conducts as part of our corporate culture.
Managing Conflicts of Interest [Principle 3]
The Asset Manager shall accurately identify potential conflicts of interest in transactions in accordance with laws and regulations and internal rules, and shall endeavor to appropriately manage conflicts of interest by, for example, consulting with a compliance committee that includes external experts prior to executing transactions in cases where conflicts of interest are identified. For details on measures to prevent conflicts of interest, please refer to MIRAI’s securities report, “Part I: Fund Information, 1. Status of Fund 1, 2. Investment Policy, (1) Investment Policy, (6) Sound Financial Base and Same Boat with Unitholders, (c) Governance System that Considers the Interests of Unitholders” (Japanese only).
Fee Transparency [Principle 4]
The Asset Manager shall clearly indicate the fee structure paid by MIRAI to the Asset Manager and disclose the actual amounts of each item along with MIRAI’s financial results. For details of fees related to MIRAI, please refer to MIRAI’s securities report, “Part I Fund Information, Status of Fund 1, Fees and Taxes” (Japanese only).
Providing Accessible, Essential Information [Principle 5]
The Asset Manager strives to provide important information concerning MIRAI, to the extent possible, in a manner that is swift, accurate, fair and easily understandable in order to ensure transparency of the asset management operation. The Asset Manager always takes MIRAI and its unitholders’ point of view, and in addition to statutory disclosures, actively discloses information that may affect the investment decisions of unitholders through MIRAI’s website, financial presentation materials, semi-annual reports, etc. The Asset Manager also strives to enhance the comprehensibility and accessibility of explanatory materials so that they can be easily understood by unitholders who may have limited financial knowledge or trading experience. (Note)
Providing Services Suited to Each Customer [Principle 6]
The Asset Manager shall endeavor to conduct appropriate asset management by understanding the needs of the customers such as MIRAI’s unitholders, and shall provide them with information in a careful and thorough manner. The Asset Manager aims to contribute to improving the sustainability of the society in which its customers live through MIRAI’s investment management business, and actively promotes initiatives related to ESG (environment, society, and governance) as issues to be addressed. (Note)
Framework for Employee Motivation [Principle 7]
In order to implement business conducts in a manner that is in the best interests of MIRAI, we have introduced a fee structure linked to MIRAI’s AUM and revenues, and appropriately reflect this in employee performance evaluations. The Asset Manager strives to provide employees with opportunities to acquire the knowledge and skills necessary to provide high-quality services to MIRAI, including through in-house training and by encouraging employees to earn qualifications, and endeavors to enhance internal education and training on compliance so that employees are aware of their social responsibilities and act in a responsible manner.
Basic Philosophy [Supplementary Principle 1]
The Asset Manager will, based on the management philosophy, with an aim to enhance MIRAI’s unitholders’ value and to ensure the sustainability of our business, will establish and implement product governance under the leadership of the management team in order to provide financial products that serve the best interest of our client, MIRAI, and its unitholders.
Establishment of Governance System [Supplementary Principle 2]
The Asset Manager has, based on Basic Philosophy, put into place a governance system ensuring third-party oversight that covers each process including conflict of interest transaction by establishing Investment Management Committee and Compliance Committee, both of which include external experts as members, in order to ensure the effectiveness of product governance throughout the entire lifecycle of asset management with MIRAI—including acquisition, disposition, and ongoing management of assets.
Measures Taken at the Formation of Financial Products [Supplementary Principle 3]
The Asset Manager examines asset acquisition for MIRAI through Investment Management Committee with respect to its medium- to long-term sustainability and its reasonableness of risk, return, and cost. Furthermore, when issuing new investment units in connection with an asset acquisition, the Asset Manager ensures sufficient information sharing with the underwriters.
Measures Taken following the Formation of Financial Products [Supplementary Principle 4]
The Asset Manager continuously verifies whether the expected characteristics of MIRAI’s assets are being maintained while the results of this verification are utilized to improve or reassess MIRAI’s portfolio and to review the overall product governance system, including the processes of asset acquisition, disposition, and ongoing management. Furthermore, in order to serve the best interests of MIRAI’s unitholders, the Asset Manager strives to verify—through information sharing with financial institutions, etc.—whether MIRAI’s management aligns with unitholders' needs and where necessary, reflects the findings to revise the portfolio or improve the structuring of future financial products.
Providing Clear Information to Clients [Supplementary Principle 5]
The Asset Manager provides clear and easy-to-understand information to MIRAI’s unitholders regarding its management framework and product governance system.
- As the Asset Manager is engaged in asset management of an investment corporation, the Asset Manager has not adopted the portions of the principles that are based on the assumption that the Asset Manager sells or recommends financial products to customers or outsources investment management.