Provisional Translation

Startup Development Five-year Plan

1. Basic Concept○ The Kishida cabinet is promoting efforts to achieve a "new form of capitalism." Startups
embody the very idea of a "new form of capitalism," which transforms social issues
into engines of growth to realize a sustainable economic society.
○ Japan's leading electronics and automobile manufacturers also began their history as
startups founded by young people in their 20s and 30s immediately after World War II
and have since become global companies that drive the Japanese economy.
○ However, as of 2022, although a diverse range of individuals taking on the challengeof creating a startup have emerged, the corporate entry rate and the number of unicorns(unlisted companies with a market capitalization of over 100 billion yen) has remained
at a low level compared to those in the US and Europe.
○ On the other hand, it has become clear that even large, existing companies using older
technologies can stay in business if they engage in open innovation, such as throughM&A with startups and collaborations with startups to introduce new technologies.
○ With the above as a backdrop, this year will be the first year of startup creation, andsecond boom in startups following the postwar period of startups will be realized. To
this end, an ecosystem that fosters startups in Japan will be created by accelerating
startups and by promoting open innovation at large, existing companies.
○ In creating this startup ecosystem, a way of thinking that is focused solely on small,
specific niches ("Galapagos thinking") will be avoided, and instead a perspective ofcreating startups that boldly challenge the global market will be taken.
○ To date, a Minister in charge of startups has been established, have clarified a unified
command post function for implementation, and, in the current fiscal year's
Comprehensive Economic Measures to Overcome Rising Prices and Realize Economic
Revival, and the Implementation of Supplementary Budget, a Cabinet Decision on 1
trillion yen worth of budgetary measures for developing startups was approved, thelargest ever. While utilizing this, from the viewpoint of building human resources andnetworks, from the viewpoint of providing funds for business growth and adiversification of exit strategies, and from the viewpoint of promoting open innovation,in order to fully mobilize policy resources over many years a five-year plan will becompiled that gives an overall picture of Japan's startup development measures by the1

public and private sectors.
2. Targets○ In order to create an ecosystem for creating and nurturing startups in Japan and torealize a second startup boom, it is necessary to set major targets and for the public andprivate sectors to work together to achieve them.
○ In terms of targets, it is important to focus not only on the "number" of startups (thenumber of businesses that are started), but also on the growth, or "expansion of scale,"of the startups that have been established. Therefore, the focus will be on the amount ofinvestment in startups as an indicator that encompasses both the absolute number ofstartups and the expansion of scale of the startups that have been established.
○ The amount of investment in startups has increased by a factor of 2.3x over the past
five years (from 360 billion yen in 2017 to 820 billion yen in 2021), and is currently inthe 800 billion yen range 1, but, by implementing this five-year plan, the public andprivate sectors will work together to achieve the major target of increasing the scale ofinvestment by more than a factor of 10x (to 10 trillion yen) by FY2027, five years fromnow.
○ Furthermore, in the future, by creating 100 unicorns and 100,000 startups, the aim will
be to make Japan the largest startup hub in Asia and one of the world's leading clusters
of startups.
3. Package Direction○ The higher a country’s average rate of firm creation and destruction (an index ofcreative destruction), the higher the per capita rate of economic growth. Furthermore,young businesses (startups) have a higher rate of contribution to added value creation.
On the other hand, the corporate entry rate in Japan remains at 5.1%, 2 compared to
9.2% in the US and 11.9% in the UK, and the corporate exit rate in Japan is also 3.3%, 3compared to 8.5% in the US and 10.5% in the UK.
○ First, a large number of startup leaders will be fostered in Japan and theirentrepreneurship will be accelerated. Then, in order to discover and foster young humanresources with outstanding ideas and technologies, practical entrepreneurship training
will be conducted, utilizing mentors and educational institutions not only in Japan but
also overseas. In addition to this, human resources who will be responsible for startup
entrepreneurship in Japan will be fostered and global network of such human resources
will be built by dispatching young human resources to countries around the world for2

training, etc.
○ In the U.S., the rate of corporate entry in the 1980s was 12%, 4 whereas currently (2019)
it is 9%. 5 However, while the number of entrepreneurship themselves is declining, theamount of venture capital investment is increasing (from $30 billion in 2008 to $60
billion in 2015). 6 In other words, support for promising companies is increasing andplays a major role in nurturing startups.
○ Therefore, in Japan as well, the supply of funds will be expanded, including public
capital, in conjunction with securing startup leaders. For this reason, in addition tofostering domestic venture capital, foreign investors and venture capital firms will also
be attracted. Additionally, from the perspective of diversifying startups' businessdevelopment and exit strategies, primarily for deep tech startups that require time togrow, the development of an environment for stock options and the expansion of public
procurement for startups will be promoted.
○ From the perspective of open innovation, significantly few Japanese companies invest
in startups compared to the US, China, and Europe ($40.2 billion for the US, $11.5
billion for China, $9 billion for Europe, and $1.5 billion for Japan (2020 figures)). 7
Japan also has comparatively few mergers and acquisitions (M&A) when compared toEurope and the US (1,473 for the US, 244 for the UK, 60 for France, 49 for Germany,and 15 for Japan (2020 figures)). 8○ When considering exits for startups and focusing on the ratio of M&As to IPOs, theratio is 90% M&As for the US, while in Japan the ratio is 80% IPOs, so Japan has an
overwhelmingly high ratio of IPOs to M&As, 9 and it is necessary to increase the ratioof M&As.
○ Thus, startup acquisitions are important both as an exit strategy for startups and as ameans for promoting open innovation in existing large companies. It is important todevelop an environment that promotes open innovation where existing companies
collaborate with startups.
○ Based on the above, in this Startup Development Five-year Plan, the following threemajor initiatives will be promoted in an integrated manner:
1. Build human resources and networks for creating startups
2. Strengthen funding for startups and diversify exit strategies
3. Promote open innovation3

○ Additionally, the fact that public support has been provided to a startup serves as acertification effect (approval) for the startups that receive support, which is said tostimulate even further private investment. In the recent Comprehensive Economic
Measures, the Cabinet Office has already approved the largest ever budgetary measures(approximately 1 trillion yen) for startup development, and, while setting KPIs forpolicy effects and following up with the Minister in charge of startups, the Government
will continue to fully mobilize its policy resources and strive to achieve a major
direction for the public and private sectors.
○ As for deep tech, which are new industrial fields that can become the core for nextgeneration industries, priority fields will be clarified. In addition, efforts will be madeto strengthen entrepreneur education and startup creation support that are specialized
for individual deep tech fields such as agriculture and medicine.
○ Tax measures will also be considered in future tax reform processes.
4. First Pillar: Building Human Resources and Networks for Startup Creation○ As mentioned above, the corporate entry and exit rates in Japan remain at a low levelcompared to the US and major European countries. In terms of the percentage of people
who consider starting a business to be a desirable occupational choice, Japan is at thelowest level among major and developed countries, at 25%, compared to 79% in China
and 68% in the US. 10○ According to a survey of startups, 60% of respondents answered that it is necessary to
improve "awareness, culture, and climate" in order to increase the number ofentrepreneurs in Japan. 11 For this reason, from a young age (such as for individuals
who are in their teens and twenties), it is necessary to promote the development of
human resources who aspire to create startups.
○ As for startup creation support at Japanese universities, the percentage of universities
that provide commercialization support, facility provision, and entrepreneurshipeducation for startups is still low but will be improved.
○ In addition, frameworks for providing support to those who actually want to start abusiness will be enhanced so that they can effectively connect their skills andknowledge to their business.
○ "Incubators," which provide startups with facilities and equipment on loan, aregradually being established in Japan as organizations to support startups. On the other4

hand, for the creation of startups it is not enough to simply provide entrepreneurs withfacilities and equipment, and it has become clear that it is essential for people withentrepreneurial experience to serve as mentors (advisors) and to provide detailed advice.
○ Furthermore, it has been found that startups receiving support from "accelerators" thatprovide mentoring functions are able to succeed (acquisition or exit) earlier thanstartups that do not receive support. 12○ This suggest that accelerator mentors are able to provide useful information to startups.
Opportunities to receive support from mentors in Japan are still limited, so it isnecessary to secure such opportunities.
○ For this reason, the following specific initiatives to build human resources and networks
for startup creation will be promoted:(1) Expand and horizontally develop of support projects by mentors○ As a program to select and support young human resources in Japan, the "MITOU
Program" (by the Information-technology Promotion Agency, Japan) in the IT field has
been discovering talented human resources (screening for adoption) and providing
guidance for projects (about 70 people per year) by first runners in the industrial andacademic world as mentors. So far, 300 people have started or commercialized theirown businesses through this program.
○ Taking this idea and then expanding it on a large scale and developing it horizontallywill be meaningful for startup development, so by horizontally expanding it to otherorganizations (such as the New Energy and Industrial Technology Development
Organization (NEDO) and the National Institute of Advanced Industrial Science andTechnology (AIST)) and expanding eligibility to young human resource development
efforts centered around students at College of technology (KOSEN), high school
students, and university students, the overall scale of the nurturing will be expandedfrom "70 people per year" to "500 people per year" in five years.
○ In addition, there will be consideration of further expanding the main entities formentor-based training of young human resources, such as by the Japan Agency for
Medical Research and Development (AMED), the Japan Science and Technology
Agency (JST), the Japan Aerospace Exploration Agency (JAXA), and the National
Agriculture and Food Research Organization (NARO).
○ In addition to providing support to carry on the achievements of the "INNO-vation5

Program," discovering top overseas talented human resources from Asia and otherregions, and strengthening efforts to attract them to Japan, with the support of overseas
accelerators there will be an expansion of global startup acceleration programs, which
implement business strategy formulation for domestic startups, mentoring with experts,
network expansion, etc.
(2) Establish entrepreneur development hubs overseas ("Dejima" programs)○ For dispatch programs that select 20 young people who want to start a business andthen dispatch them to Silicon Valley, over the next five years the scale of dispatches
will be expanded to about 1,000 people. In doing so, the program will be structured torecruit a wide range of human resources, including students and female entrepreneurs.
In addition, from the perspective of securing opportunities to receive guidance frommentors, which are still restricted in Japan, intern trainings, etc. will be added at US
cities that are hubs of innovation (such as Silicon Valley, Boston, New York, San Diego,and Austin) and at startups, venture capital firms, and accelerators, etc. in Israel,
Singapore, Northern Europe, and other parts of the world. Furthermore, hubs forJapanese businesses will be newly established in Silicon Valley and Boston.
(3) Enhance entrepreneurial education, including the establishment of entrepreneurshipdevelopment programs for Japan at US universities○ When it comes to fostering entrepreneurs in Japan, there are limits to providing
educational programs with global strengths. For this reason, the establishment of an
MBA program for fostering entrepreneurs in Japan at American universities will beconsidered, and the environment will be improved so that people can earn a degree
while working in Japan.
(4) "One University, One Exit" movement○ Although many university-launched startups are located in metropolitan areas such as
Tokyo, Kanagawa, Kyoto, Osaka, and Fukuoka, startups are being born all over Japanand there is also potential in rural areas.
○ In order to support the creation of university-launched startups, research universities
across Japan will develop a movement to "start 50 companies per university, with one
company aiming to exit'."(5) Support startup creation at universities and for elementary, junior high, and high school
students○ In consideration of the fact that nearly half of university students also want to work forstartups, it is important to provide these prospective students with opportunities to6receive entrepreneurship education and support from mentors and accelerators.
○ Centered on the eight cities in the Startup City Project Japan and with the participationof overseas accelerators and venture capital firms, including global expansion, thecommercialization of university research results for more than 5,000 projects in five
years will be supported.
○ For this reason, a new fund of 100 billion yen for five years, which is 10 times the scaleof the current fund, will be created at the Japan Science and Technology Agency.
○ The introduction of a "cross-appointment system" that allows researchers, etc. toconclude employment contracts with both companies and universities/KOSEN will bepromoted.
○ Startup incubation facilities at universities will be developed. In addition, efforts will
be made to match technology seeds from universities and national research institutes(such as the AIST) with management personnel from large companies.
○ In addition, a support program for entrepreneurship education that invites entrepreneurs
as lecturers will be newly established for elementary, junior high, and high school
students, and entrepreneurship education will be expanded for elementary, junior highand high school students by utilizing class hours such as "integrated study" classes.
○ Furthermore, support for educational opportunities will be strengthened for highschools and KOSEN that systematically engage in entrepreneurial education and forelementary, junior high and high school students with high abilities in STEM fields. 13○ Currently, annual study abroad is supported for 16,000 undergraduate and graduate
students and 1,400 high school students, but, in addition to some undergraduate andgraduate students who receive education in the US and Europe feeling burdened by therepayment of large amounts of scholarships, in order to spread the entrepreneurial spirit
in Japan it is also meaningful to have junior high and high school students study abroadand gain learning experiences overseas. For these reasons, Japan will aim to expand
support over the medium to long-term.
(6) Enhance entrepreneurship education at KOSEN○ For KOSEN, in addition to actively promoting entrepreneurship education at KOSEN,
collaborations amongst KOSEN will also be promoted to utilize their high technicalcapabilities.
7

○ Additionally, the environment will be improved for KOSEN that are engaged inentrepreneurship education that utilizes AI and deep tech, such as by creating spaces
for making prototypes, which will enable free production activities and practical classes.
(7) Global startup campus concept○ In order to contribute to the global expansion of human resources and to research seeds
from Japanese universities and research institutes, a global startup campus will becreated through public and private funding that combines international joint researchand incubation functions in deep tech fields by attracting top overseas universities andby inviting outstanding researchers.
○ In doing so, the aim will be to promote the establishment of long-term and stablecooperative relationships with top overseas universities, etc., and in managing thecampus, the aim will be to build the campus's own endowment (university fund) andrealize strategic management.
○ Additionally, the establishment of the campus will revitalize research and development
at domestic universities and encourage reforms. Furthermore, rather than waiting forthe completion of campus facilities and equipment, joint research and researcher
exchanges with overseas universities, etc. will be proactively implemented, working toquickly create startups. In addition, these initiatives will work to develop doctoral
course students and young researchers who will play an active role not only in academic
fields, but also in startups and venture capital firms.
○ Access to overseas ecosystems and global inner circles will also be possible throughthe utilization of entrepreneur training and incubation programs held by overseas
universities and the formation of networks with top overseas venture capital firms.
○ Collaborating with domestic and foreign companies will improve the ability ofdomestic companies to create innovation through joint research and entrepreneur
development programs on global startup campus.
○ In cooperation with relevant local governments and from the perspective ofstrengthening the ecosystem through urban planning, a truly global campus will beformed by promoting measures in an integrated manner, such as by improving the living
infrastructure for foreign human resources.
○ This initiative will be a free "place of practice" that is not bound by the rules of existing8

organizations, and, from that point of view, under the Minister in charge of Startups
who will act as a “guiding light” function, there will be coordination on a variety ofmeasures with the aim of creating the campus in a centralized and efficient manner.
(8) Intellectual property strategy for startups and universities○ In order for startups to smoothly utilize intellectual property owned by universities, etc.
and to develop their own business, the rules for handling non-exclusive licenses ofpatents jointly owned by universities and companies will be reviewed, the developmentof an environment that facilitates the use of startup stocks and share warrants (including
abolishing restrictions on the university side when intellectual property rights owned
by universities are acquired by startups in exchange for stocks and share warrants) will
be considered, and "University Intellectual Property Governance Guidelines" will becompiled within the current fiscal year. Additionally, support for overseas patentapplications by universities will be strengthened.
○ In conjunction with this, there will be work to enhance databases and to strengthen
public-private cooperation, including the transfer of data on the “Licensable Patent
Information Database”, which registers patents with the intent of licensing ortransferring them to third parties, to the private sector. In addition, the types of
incentives for licensing owned patents to third parties will also be considered.
(9) Expand researchers in research fields○ In order to promote the entry of Japanese researchers into the top circles of international
research and to acquire outstanding young researchers from overseas and to strengthen
connections through joint research, support for international joint research with theparticipation of young researchers as a requirement ("Grants-in-Aid for Scientific
Research - KAKENHI -International Leading Research") will be provided with thecondition that, in principle, 70% of the total expenses are spent on young researchers.
○ In order to realize world-class research universities, support, based on the Universities
for International Research Excellence Act, will be provided through the 10-trillion yen
University Endowment Fund. Additionally, there will be efforts to improve thetreatment of doctoral course students and to improve research environments for them,with the aim of tripling by 2025 the number of doctoral course students who receive anamount equivalent to their living expenses (approximately 70% of doctoral course
students who have entered doctoral course directly after the completion of mastercourse).
○ As further support measures for doctoral degree holders, additional salary grades, etc.
9

will be introduced in the public employee recruitment process for individuals who havecompleted a doctoral course (such as implementing additional starting salary measures
in FY2023 amongst national public employees for individuals who have completed adoctoral course), and the inclusion of doctoral degrees on the business cards of public
employees will be encouraged. A change in the awareness of the use of doctoral degrees
in private companies as well will also be encouraged.
(10) Attract more foreign entrepreneurs and investors○ Currently, foreign entrepreneurs are permitted to enter and stay in Japan for up to one
year on a Startup Visa (Foreign Entrepreneurship Promotion Project), but the persons
confirming this visa are limited to local governments that are authorized by the national
government.
○ In order to further accelerate attracting foreign entrepreneurs in the future, not just local
governments but also private organizations such as venture capital firms andaccelerators authorized by the government will be able to perform the Startup Visa
confirmation procedures, and the maximum period of stay will be extended.
○ In addition, the granting of status of residence so that overseas investors can be activein Japan will be facilitated. Furthermore, efforts will be made to facilitate proceduresfor foreign individuals to open bank accounts.
○ The development of the living infrastructure necessary to acquire highly skilled global
human resources will also be promoted, such as by smoothly granting university
entrance qualifications to foreign children who have graduated from international
schools, establishing multilingual and online facilities at government agencies andmedical facilities, and making more services and functions available online.
(11) Develop an environment that supports repeated attempts○ In 2022 the Employment Insurance Act was amended and a new system was establishedso that unemployment benefits, which individuals in principle originally lost eligibility
for one year after leaving their job, would not be included in the individual's benefit
period for a maximum of three years during which the individual has started and beenrunning a business. There will be further work to develop an environment thatencourages entrepreneurs to take on new challenges, such as by sufficiently publicizing
this system.
(12) Promote the formation of domestic entrepreneurial communities○ In order to create in Japan as well an even more entrepreneurial community that10

accelerates global expansion, regulatory reforms will be advanced, the J-Startup will be
expanded, and the environment for startups will be improved, such as by developing
incubation facilities.
○ University support forums such as PEAKS 14 will be utilized as places for people
involved in universities, startups, and venture capital firms, etc. to share with and traineach other on best practices in ecosystem building.
5.

Second Pillar: Enhancing Funding provision for Startups and Diversifying Exit
Strategies○ In the US, a variety of financing methods are available according to a startup's growthstage. Whether it be for IPOs, public stock offerings, private equity funds, venture
capital firms, or corporate venture capital, in the US the scale of all of these financing
methods greatly exceeds the scale in Japan.
○ With regard to the amount of venture capital investment in 2021, the amount ofinvestment and number of cases remains small in Japan (230 billion yen, 1,400 cases).
Additionally, compared to the amount of investment in 2020, the amount of investmentin the US (36.2 trillion yen, 17,100 cases) doubled, while the amount of investment inJapan only grew by a factor of 1.5x, so growth is also low. 15○ Comparing companies that have received venture capital investment with those thathave not, the companies that received investment have been more proactive about
creating employment and innovation. That is to say, it has been confirmed that venture
capital firms have significant abilities for evaluating startups and also have the ability
to nurture startups.
○ In order to expand venture capital investment in Japan, the Government will expand
investment through limited liability investment of public capital into venture capital,
including overseas venture capital, and will expand government support for startups incooperation with venture capital.
○ Additionally, from the perspective of diversifying business development and exit
strategies for startups, the development of an environment for stock options and the
expansion of public procurement will be promoted.
○ In order to do so, the following specific measures to strengthen startup funding
provision and to diversify exit strategies will be promoted:

11

(1) Strengthen the functions of the Organization for Small & Medium Enterprises andRegional Innovation, JAPAN to invest in venture capital○ Organization for Small & Medium Enterprises and Regional Innovation, JAPAN (SME
Support JAPAN) has a track record of investments and there will be a 20 billion yen
strengthening of its investment functions, bearing in mind that it will make new limited
liability investments in domestic and foreign venture capital that have the financial
strength and know-how to foster startups.
○ Furthermore, with regards to the new medium-term goals and plans by SME SUPPORTJAPAN from FY2024, in addition to setting goals to further strengthen limited liability
investment functions, there will be consideration for supporting the development ofdomestic venture capital firms, such as by establishing investment quotas that arelimited to venture capital firms run by young capitalists, and for reviewing the upper
limit of debt guarantee systems for deep tech startups.
(2) Strengthen investment functions of the Japan Investment Corporation○ Japan Investment Corporation (JIC) has a track record of investing in startups througha 120 billion yen fund over the previous four years.
○ In addition to launching a new fund that will double JIC's investment scale, JIC's
investment functions will be further strengthened by submitting a bill around 2024 andextending JIC's operational period to 2050 (JIC's current operational period is until2034).
(3) Strengthen the investment functions of public-private funds, etc.
○ Limited liability investments in domestic and foreign venture capital firms by publicfunds will be strengthened, including for public and private funds other than those by
SME SUPPORT JAPAN and JIC, and there will be sufficient risk money supplied torealize a 10x or greater increase in startup investment in five years.
○ For public-private funds, functions to gather information from overseas and to attract
investors will be strengthened, and, in order to strengthen the networks between
overseas venture capital firms and Japanese startups, etc., overseas hub functions andinvestment functions for overseas venture capital firms will be strengthened while
collaborating with NEDO and the Japan External Trade Organization (JETRO). In
doing so, cooperation and collaboration from discerning gatekeepers (advisors) such asprivate financial institutions, etc. will also be obtained.
○ Additionally,collaborations

between12

government-affiliatedstartup

supportorganizations will have their unified information dissemination strengthened and theireffectiveness as central points of contact will be enhanced.
○ Further utilization of the specific investment business of the Development Bank ofJapan (DBJ) will be promoted.
(4) Strengthen support measures for R&D startups by NEDO
○ In order to bridge the gap between the technology seeds of R&D startups andcommercialization, and on the condition that 1/3 of the amount equivalent to the costof practical application development be invested by certified venture capital firms,
NEDO will provide subsidies for the remaining 2/3 of the amount.
○ In the future the upper limit of this subsidy will be increased, the support menu will be
expanded, and the number of eligible venture capital firms including overseas venture
capital firms, will be increased. To do so, a new, five-year 100 billion yen fund (20billion yen per year) will be created, which is three times the size of the current fund (6billion yen per year). In doing so, efforts will also be made to simplify the procedures,in consideration of the burden on startups.
(5) Enhance support for drug discovery ventures by AMED
○ With support eligibility limited to infectious diseases for drug discovery ventures andon the condition that 1/3 of the amount equivalent to the cost of practical application
development be invested by certified venture capital firms, AMED will provide
subsidies for the remaining 2/3 of the amount.
○ In the future support eligibility will be expanded to drug discovery for fields other thaninfectious diseases, where it is difficult to raise funds, and, to do so, a total of 300 billion
yen spread across 10 years (30 billion yen per year) will be added to the fund. In doing
so, efforts will also be made to simplify the procedures, in consideration of the burden
on startups.
(6) Strengthen connections with advanced overseas ecosystems○ In Boston, the evolution of the startup creation and nurturing model has led to the earlyexit of biotech startups, as venture capital firms in the biotech field have assembled
highly specialized capitalists and have begun providing support in collaboration with
universities, hospitals, pharmaceutical companies, and others from the basic research
stage before the company is launched. The connections between the world's mostadvanced ecosystems like this and the ecosystem of drug discovery startups in Japan
will be strengthened.
13

(7) Measures to encourage investment in startups○ A preferential tax system will be established for the sale of shares held by founders andother individuals and reinvestment in startups so that startups can be supplied withfunds from individuals such as startup founders.
○ As for the angel taxation system, there will be consideration of simplifying theprocedures and moving the procedures online, such as by reducing the application
documents that are required to receive the tax incentives.
○ Additionally, in order to promote angel investment, the spread of platforms for
information sharing and matching between angel investors and startups will bepromoted.
○ Measures for dealing with future social entrepreneurs (impact startups) will beconsidered.
(8) Promote investments from individuals to venture capital firms○ In consideration of the fact that a great deal of individual funds in other countries areinvested into venture capital firms and while keeping investor protection in mind, there
will be consideration, including tax measures, to further promote investments instartups from individuals through venture capital firms.
(9) Improve the environment for stock options○ In Japan the amounts raised through IPOs are smaller than in the US and Europe, andit has been pointed out that startups are rushing toward IPOs. It is important for startups
that require time to commercialize, particularly those in deep tech sectors, and startups
that want to remain unlisted for an extended period of time in order to expand theirbusiness, to be able to flexibly choose the timing of their IPO.
○ Stock options, which are used globally as compensation for startup employees, should
also be able to be used via simple procedures and with flexible exercise (listing) timingin accordance with the growth speed of the startup's business.
○ For this reason, the period for exercising rights in the stock option taxation system forstartups will be extended.
○ Additionally, the obligation to entrust the stock certificate custody for tax-qualified
stock options, which is currently required when rights are exercised while a company
14

is unlisted, will be eliminated and there will be a further relaxation of these regulations.
○ In the US there is widespread usage of so-called stock option pools, in which a certain
amount of stock option issuance limits are set in advance and stock options are thenflexibly granted to employees. In Japan, the Companies Act requires that stock options
be granted to employees within one year of the establishment of a stock option tranche
based on a resolution at a general shareholders' meeting, and such flexible issuance ofstock options is not permitted. While referring to the example of the US, theenvironment for realizing stock option pools in Japan will be improved, including
revisions to the Companies Act measures and taxation measures.
○ Furthermore, the issues that startups face when utilizing stock options, such as the useof stock option pools and the handling of stock options when employees retire or leave
the company, will be consolidated and clarified in guidelines.
○ The rules on how to measure the price of class shares in the case of unlisted companies
are unclear, which hinders the granting of stock options as compensation. Throughguidelines and other means, the rules for calculating the price of class shares will beclarified. At the same time, there have been comments that it is not clear when a special
resolution at a general meeting of class shareholders is required for class shares. As
such, while also taking into account actual needs, the necessary considerations will be
conducted, including clarification of requirements.
○ The actual situation for trust-type stock options (a system in which stock options are
granted via a trust company) will be investigated and necessary measures will be taken
according to the results.
(10) Develop an environment for the utilization of Restricted Stock Units○ A Restricted Stock Unit (RSU) is the right to be granted shares after a certain period of
employment, and they are commonly used in the US as compensation and incentives
from startups with limited cash reserves. On the other hand, in Japan it is unclear
whether RSUs fall under the disclosure requirements for new share issuances of 100
million yen or more per year, as stipulated in the Financial Instruments and ExchangeAct, and there have been comments that this is an obstacle to the introduction of RSUs.
The handling of RSUs will be clarified.
(11) Improve environment for the use of equity investment crowdfunding○ Equity investment crowdfunding is a system in which an unlisted company issues
shares and collects small amounts of funds from many people on the internet. Necessary15

revisions will be made to this system while also taking into account actual needs andinvestor protection, such as considering the possibility of raising funds fromprofessional investors in excess of the current maximum total issuance amount (100million yen).
(12) Drastic review of the Small Business Innovation Research system and promotion of
public procurement○ Utilizing public procurement is important for nurturing startups. With reference to the
Small Business Innovation Research (SBIR) system in the US, the SBIR system inJapan will be drastically expanded to support companies (startups) that have just been
established.
○ Procurement from startups will be expanded in areas where the ratio of contracts fromsmall and medium-sized enterprises (SMEs) established less than 10 years is only about
1% (77.7 billion yen (FY2020 results)) for properties, construction, and services
procured by the national government, independent administrative agencies, and othergovernment agencies, and the contract ratio will be rapidly expanded to 3% or more (toapproximately 300 billion yen).
○ The Minister in charge of Startups will follow up on the implementation status of themeasures and will encourage the responsible ministries to correct the situation if themeasures are not being achieved.
○ Under Japan's current SBIR system, a total of 7 billion yen in R&D-related subsidies
from the various ministries are combined to support R&D in the FS survey phase forbusiness ideas ("Phase 1") and in the R&D phase for commercialization ("Phase 2").
Together with expanding these subsidies, the large-scale technology development anddemonstration phase ("Phase 3") will also be newly added as eligible for this support.
○ In doing so, not only will the Cabinet Office compile the R&D-related subsidies fromeach ministry and designate them, but the Cabinet Office will also create a new, fiveyear, 200 billion yen fund (40 billion yen per year) to further reinforce this Phase 3
R&D.
○ Additionally, the use of startups (including the use of those selected as J-startups) will
be promoted in a wide range of government procurement, including for public
infrastructure (railways, electricity, and water).
○ In order to expand the participation of startups in government procurement, a bidding
16

participation qualification system will be considering, including consideration of rules
on free contracts and measures that grant additional points for large-scale national
research.
○ The following measures will be promoted to comprehensively promote public
procurement by local governments:
 In addition to unifying the different documents and forms for each local
government, making procedures available online will also be encouraged.
 In addition to encouraging a cross-sectional review of procurement participation
requirements that differ for each local government, procurement by local
governments and private businesses will be encouraged through visualization of
the state of public procurement by the national government.
 Measures such as granting additional points to procurement from startups whenreviewing the adoption of the subsidy for the Vision for a Digital Garden City
Nation to promote digital implementation in rural areas will be taken.
 A digital marketplace that catalogs the specifications of services provided by IT
companies, including by startups, and that makes it easier for the government toprocure services that meet their requirements will be demonstrated during FY2023,
with the aim of introducing it early.
(13) Review systems to eliminate the need for personal guarantees from managers○ 77% of those interested in starting a business cited "incurring a loan or personal
guarantee" as the key risk brought about by business failure. In fact, when establishing
their business, currently 47% of entrepreneurs provide personal guarantees, includingloans with credit guarantees, when borrowing from private financial institutions. 16○ A new credit guarantee system that does not require personal guarantees for startups
less than five years old will be created. For this purpose, 12 billion yen will be provided
as compensation for losses to credit guarantee associations.
○ Additionally, for loans provided by the Japan Finance Corporation (JFC), a loanrequirement will be set such that a manager's guarantee is not required within five yearsof a startup's founding. Furthermore, capital loans will continue to be provided tostartups with insufficient cashflow and to SMEs whose financial situation has
temporarily deteriorated. In order to do so, additional investments will be made in JFC.
○ In conjunction with this, the relevant ministries and agencies will compile measures
within the current year to establish financing practices that do not rely on manager
guarantees.
17(14) Develop the IPO process○ In line with the "IPO Process Review" from April of 2022 and based on the review, thesecurities industry and competition authorities will steady review the IPO system andimprove its operation. Additionally, listing examination for companies for which it isdifficult to assess their corporate value, such as deep tech startups that utilize newtechnologies in cutting-edge fields, will be realized, and direct listings, wherein only
existing shares are listed without the issuance of new shares, will also be utilized.
(15) Consideration of SPAC (Special Purpose Acquisition Companies)○ The amount of funding raised per IPO is $300 million in the US and $200 million in
Europe, but only $60 million in Japan. Additionally, according to an international
comparison by a US research company, there are 633 US, 173 Chinese, and 147
European unicorns (private companies with a market cap of over $1 billion). Japan, in
contrast, has only six unicorns. 17○ Consideration will be given to the necessary systems should SPAC (Special Purpose
Acquisition Companies) be introduced, taking into account trends in international
financial markets and giving due consideration to investor protection.
(16) Creation of a secondary market for unlisted stocks○ Currently, private trading systems (PTS) operated by securities companies are notpermitted to handle unlisted stocks even for professional investors. In order to enable
the handling of unlisted stocks for professional investors so that startups can growwithout being listed, the relevant Cabinet Orders for the Financial Instruments andExchange Act will be revised during FY2023.
○ At the same time, the development of an environment for facilitating transactions in thesecondary market will be promoted, for example by promoting efforts by the private
sector to standardize data such as the securities of unlisted companies.
(17) Review the private placement system for professional investors○ In July 2022 the Japan Securities Dealers Association (JSDA) revised its rules regarding
the private placement system for professional investors, which allows startups to solicit
applications to acquire newly issued securities, from professional investors only, as ameans of raising funds, and made the system available for unlisted securities as well.
On the other hand, there have been some comments that there is a heavy administrative
burden on startups for the specified securities information (corporate information andbusiness performance, etc.) that is newly required to be provided or disclosed under the18

new regulations. Based on this, the utilization status of the new system will be followed
up on and revised as necessary while also taking into account actual needs and theperspective of investor protection.
(18) Tax measures related to the departure tax, etc. to promote overseas expansion○ In order to promote the overseas expansion of startups, when a startup is expanding
overseas and when a manager himself/herself will be posted overseas, it should be
confirmed and made known that it is possible for the manger to leave Japan with thecompany's guarantee and without the manager having to provide his/her own startup
shares as collateral. In the same way, employees, etc., are not required to offer theirshare certificates as collateral if they pledge their shares.
(19) Develop the Web 3.0 environment○ With regards to crypto assets that are issued and held by corporations engaged in crypto
asset businesses, measures will be taken so that these assets will not be subject to theyear-end mark-to- market valuation taxation of corporate taxes if the crypto assets arecontinuously held for the purpose of operating the business.
○ The tax treatment for other crypto assets as well will be considered based on their legal
and accounting treatment.
○ In March 2022 the Accounting Standards Board of Japan (ASBJ) organized andannounced discussions to address issues on accounting for crypto asset businesses areunderway. Based on these discussions, the government will promote an environmentthat enables audits by certified public accountants and audit firms.
○ By clarifying that LPSs are eligible for investing in businesses dealing in so-called
security tokens, which are tokenized securities, and other businesses dealing in crypto
assets and other tokens, encourage diversifying of investments in businesses dealing inthem.
○ In addition, the benefits and challenges of blockchain-based DAO (Decentralized
Autonomous Organizations), which are expected to be used for regional revitalizationand the resolution of social issues, will be quickly sorted out.
○ Discover and support new uses cases for the international expansion of art, games andother content businesses that use digital technologies.
○ Professionals who can handle advanced digital technologies such as blockchain
19technologies will be secured and fostered.
○ In order to promote collaboration between Japanese startups and overseas experts withadvanced skills and expertise, an environment will be created where overseas experts
can play an active role by creating networking opportunities for the collaboration
between domestic and foreign Web 3.0 experts.
(20) Create business growth collateral○ In order to develop an environment in which startups, etc. that do not have many
tangible assets can procure growth funds in an optimal way, it will be effective forfinancial institutions to evaluate the business itself, such as its business value and its
future potential, and then provide financing without relying on real estate collateral, etc.
○ As such, in order to create a system that in which startups can procure growth funds
from financial institutions by using the entire business as collateral, the aim will be toquickly submit the relevant bills to the Diet.
(21) Redirecting personal financial assets and long-term investment funds such as GPIF toventure investment○ In addition to redirecting the 2,000 trillion yen of personal financial assets in Japan
toward nurturing startups, pathways will be developed to redirect long-term investment
funds such as GPIF to venture investment and infrastructure provision.
○ For this reason, Doubling Asset-based Income Plan will be promoted in order to redirect
personal financial assets to nurture startups by promoting venture investments fromangel investors and by investing in domestic venture funds such as pension funds.
○ Additionally, from the perspective of benefits for the insured, etc., such as sustainablegrowth of the overall market and risk reductions and performance improvements
through diversified investments, public institutional investors such as GPIF will work
to develop an environment for expanding the supply of funds to domestic startups,
which are growth engines, through investments in domestic venture funds.
○ With regard to corporate pension plans, we will encourage the plans to accept the
Stewardship Code, which aims to increase the medium- to long-term investment returnsof the beneficiaries, and encourage listed companies to work on human resources andoperational initiatives based on the Corporate Governance Code.
(22) Promote startup financing by banks, etc.
20

○ As for supply of funds to startups through loans, the state of support for startups will
be flexibly confirmed and followed up on through interviews, etc. while also
monitoring banks, etc. based on strategic priorities, etc.
○ Normally, the Banking Act prohibits banks from investments of more than 5% in
business companies. However, in 2021 the Banking Act was amended to expand an
exception, thereby allowing banks to make investments of more than 5% in startups
that have been established for less than 10 years. In the future, sufficient awarenessactivities on this change will be conducted, the implementation status will be followed
up on, and banks will be encouraged to actively invest in startups.
○ In addition to the above, the environment will be improved to promote financing frombanks in Japan to startups, for example in the JFC's startup support system, by making
the financial industry (FinTech companies) eligible for financing after having been
screened that there is no risk in lending to them.
○ The formation of funds by financial institutions and investments in startups by regional
financial institutions will be promoted. Additionally, it will be clarified and awarenesswill be spread that continuous investments from banks to startups will not be subject torestrictions such as those for speculative unlisted stocks.
(23) Develop a social entrepreneurship ecosystem and promote impact investments○ Even in Japan, when younger people think establish a startup, they often aim ofaddressing social issues such as environmental problems or concerned with raisingchildren. In fact, the top motivation for wanting to create a startup in Japan is "Wanting
to solve social issues and wanting to be of service to society" (73.7% (2021questionnaire survey for startups)). 18○ For this reason, at domestic universities the development of educational programs andof networks related to social entrepreneurs (impact startups) will be supported, and thecreation of hubs for fostering social entrepreneurs will be promoted.
○ Overseas dispatch programs for young people who aspire to becoming social
entrepreneurs will be promoted.
○ As for services that have been handled by the public sector up until now, it is expectedthat the private sector will be proactively involved in order to respond to diverse needs
in a detailed manner. Japan is said to be a developed country that is facing challenges,
will take the lead in the world in recognizing social issues as energy for growth, and21

will build systems into the economy and society to resolve them.
○ To this end, in order to promote impact investments and to strengthen support for social
businesses, etc., there will be consideration of new forms of corporations that play
public roles in the private sectors, reforms of existing corporations, and the creation ofa Japanese version of the certification system for impact startups that is based on theinternational certification.
○ In order to support social entrepreneurs (impact startups), the following items will beconsidered: Incentives in public procurement
 Inclusion on list of recommended companies provided from the national
government to local governments
 Matching with local governments
 Support measures for investment
 Utilization of the hometown tax payments (furusato nozei) and the corporate
version of the hometown tax payments
 Utilization of dormant deposits
 Promotion of Pay for Success (Social Impact Bonds, etc.) by national and local
governments
 Support by investment funds○ Basic guidelines for expanding impact investment will be compiled, and the spread of
impact investment will be promoted.
(24) Attract overseas startups and strengthen the overseas expansion of domestic startups○ In addition to promoting the dissemination of information related to Japanese startups
and support systems to overseas venture capital firms, startups, and entrepreneurs,
business matching will also be strengthened. The Council for Promotion of Foreign
Direct Investment in Japan will also position startups as a priority area in the new action
plan that will be formulated around spring 2023 and will work to enhance related
measures.
○ In addition to strengthening networking at global events related to startups, global
human resources matching will be promoted along with overseas technology
demonstrations and joint research.
(25) Improve the environment for attracting foreign investors and venture capital firms○ Unlisted shares held by funds are valued at their fair value (market value) overseas, but
22

in Japan they are often valued at their acquisition cost. In order to enable international
comparisons of the performance of Japanese venture capital firms and to promote
attracting foreign investors, important matters in auditing venture capital firms and thepractical handling in terms of accounting treatment will be clarified, and theintroduction of fair value assessments in Japan will be promoted.
○ Currently, LPSs are allowed to invest in securities issued by foreign corporations atleast 50% of the total capital contribution of all partners only if certified by the Act on
Strengthening Industrial Competitiveness. Facilitating overseas investments byventure capital firms, the upper limit of the overseas investment ratio in laws andregulations related to LPS investments will be eliminated. Additionally, clarify thetreatment of LPS accounting rules by positioning them in laws and ordinances.
○ There are opinions that there are instances in which Japanese contract forms, etc.
become barriers to entry for foreign investors, or in which venture capital firmmanagers and employees may not be able to operate under the same conditions as
overseas in terms of taxation and labor laws, etc. As such, while taking into account theactual practices of foreign investors, there will be promotion for the development of aworld-class environment in which foreign investors and global top talent from Japanand overseas can easily work in the Japanese startup ecosystem, such as by creating anddisseminating model contracts that are in line with global standards.
(26) Enhance startup creation in regional areas○ In addition to the efforts of Startup City Project Japan and J-Startups, national
university investments into regional funds in which regional financial institutions
participate will be increased, and support for startups by regional universities will bestrengthened.
○ Proactive support for startups by regional financial institutions will be provided throughthe promotion of investment in regional startups by regional financial institutions, andthe promotion of human resources matching between large companies and mainstay
corporations and SMEs including regional startups.
○ There will be support for the development of next-generation satellite offices wherestartups in a variety of fields and the businesses that support them can gather and which
the entrepreneurial community (including local universities and financial institutions)
can utilize as bases for their activities.
○ The use of PFI, etc. (multiple businesses working together to develop facilities,
23

equipment, and digital infrastructure that can be shared with local social services) will
be promoted for mutual assistance-type social businesses.
○ There are limited locations where companies in deep tech fields can conduct
demonstration experiments while ensuring safety, so, with the cooperation of local
governments and of the companies and residents in the surrounding areas, deep techdemonstration sites will be created and expanded.
(27) Support for startup creation in Fukushima○ In the coastal region of Fukushima Prefecture, there will be work on the developmentof demonstration fields so that robots, drones, and eVTOLs (electric Vertical Take-off
and Landing), etc. can be smoothly demonstrated in an environment that is closer tothat of actual use.
(28) Utilize startups at Expo 2025 Osaka, Kansai, Japan○ Startup technologies will be actively utilized at the Expo 2025 Osaka, Kansai, Japan,
which is called "People’s Living Lab."
6. Third Pillar: Promoting Open Innovation○ It is not easy for outstanding existing companies to maintain their growth rates.
According to discussions on traditional disruptive innovation, companies that have beenusing old technologies will inevitably lose out to companies that have entered themarket using new technologies. However, recent research has confirmed that evencompanies using older technologies can stay in business if they collaborate withstartups to introduce new technologies. Investment in startups is important to promote
open innovation by large, existing companies.
○ For this reason, the following specific initiatives to promote open innovation will bepromoted:(1) Tax measures, etc. to promote open innovation○ In order to promote M&A, which is an exit strategy for startups to significantly growunder the umbrella of a business company, tax measures, limited to those that will
particularly contribute to the growth of startups, under the open innovation tax system
will be provided for the acquisition of existing shares that have been issued. In doingso, sufficiently effective tax measures will be adopted.
○ Additionally, the preferential R&D tax system will be expanded for when a company
is collaborating with startups.
24

○ Measures to promote investment from business companies to venture capital firms will
be considered.
(2) Review public stock offering rules○ Currently, when conducting a public stock offering, the JSDA's self- regulations
stipulate that, in principle, the funds must be allocated within one year of when a public
offering is made, and this has become an obstacle to M&A of startups by large
companies. In the future these self- regulations will be revised, such as by abolishingthe deadline for allocating funds, with implementation in mid-FY2023.
(3) Establishment of voluntary liquidation legislation for business restructuring○ Due to the COVID-19 pandemic, the debt balances of Japanese companies havecontinued to increase, and more than 30% of companies believe that debt is a holding
them back from restructuring their businesses. In European countries there are legal
systems for business restructuring where, under the approval of a court and without
requiring the consent of all lenders, rights modifications can be made via a majority
vote and the business restructured, but this kind of system does not exist in Japan.
○ Therefore, in order to facilitate business restructuring by Japanese companies, a bill tofacilitate business restructuring for voluntary liquidation will be submitted to the Diet
so that voluntary liquidation (debt liquidation) can be done by a majority vote ofcreditors with the approval of a court and without seeking the consent of all creditors.
(4) Smooth labor mobility to startups○ In order to nurture startups, it is important to review Japan's employment practices, suchas working styles based on lifetime employment, the prohibition on side jobs andsecondary jobs, and the overdependence on simultaneous hiring of new graduates, andto facilitate the movement of human resources.
○ Securing human resources with a Ph.D. is particularly important in deep tech, etc., anda shift away from the overemphasis on hiring new graduates all at once is required.
○ In order to give workers the opportunity to move their labor to startups, by June 2023
the "Guidelines for Facilitating Labor Mobility" will be compiled with the goal of
simultaneously resolving the three issues of 1) Facilitating labor mobility without
unemployment between companies and industries, 2) Investing in people for reskilling(retraining to move to growth fields), and 3) Against this background, structural wage
increases.
25

○ When the guidelines are compiled, sufficient consideration and thought will also begiven to the transfer of human resources to startups.
○ In particular, in order to contribute to facilitate labor mobility to startups, labor policies
will strengthen the promotion of side jobs and secondary jobs and will support
companies that send out personnel for side jobs or accept personnel for side jobs. In
addition, support for startups in the form of secondment of human resources from large
companies will be strengthened.
○ Consultation with and support by experts in management, legal affairs, and intellectual
property, etc. will be strengthened for startup commercialization. Additionally, support
will also be strengthened such as by connecting intellectual property strategy experts tostartups through venture capital firms.
○ Consideration will be given to how information disclosures and governance should bewhen a large company provides its own intellectual property rights, human resources,or other management resources to a startup, and the "Intellectual Property andIntangible Assets Governance Guidelines" will be revised within the current fiscal year.
(5) Consider further accelerating organizational restructuring○ From the perspective of demonstrating the potential of large companies' management
resources (human resources, technology, etc.) and creating startups from large
companies, it is important to promote spin-offs. Therefore, even if a portion of theequity remains with the company conducting the spin-off, it will not be subject totaxation.
○ In addition, measures to promote bold business restructuring will also be considered.
(6) Expand the voluntary application of the International Financial Reporting Standards(IFRS) to promote M&A○ Japanese accounting standards stipulate that goodwill is amortized on a regular basis,such as by the straight-line method. There have been comments that this accounting
standard has made companies cautious about M&A because the cost of amortizing
goodwill will continually put pressure on the acquiring company's earnings. For thisreason, companies will be urged to expand the voluntary application of the International
Financial Reporting Standards (IFRS), which do not amortize goodwill.
(7) Collect and organize data to understand the overall picture of the startup ecosystem26

○ In order to accurately understand the trends around the startup ecosystem and to
consider the necessary policies, data will be collected (such as by conducting factfinding surveys) and organized in a form that enables international comparisons.
(8) Promote open data on public services and infrastructure○ Compared to large companies, startups have fewer human resources to allocate to
information gathering, and it is not easy for them to access information on public
services and infrastructure held by the government, which makes it difficult for them
to be able to consider the possibility of using their own technologies.
○ National and local governments provide information on the Internet about public data,
which startups can utilize.
(9) Strengthen the networks of large companies and startups○ In order to promote smooth open innovation, awareness will be spread about"guidelines" that should be kept in mind regarding non-disclosure agreements andlicense agreements, etc. for when startups and business companies, etc. collaborate.
○ Networks will be strengthened through J-Startup and the Japan Open Innovation
Council (JOIC).
End of Document27

<List of Sources and Annotations>
1
2
3
4
5
6
7
8

9
10
11
12
13
14
15

16

17

18

INITIAL, "Japan Startup Finance"
Small and Medium Enterprise Agency, "2022 White Paper on Small and Medium Enterprises inJapan"
Small and Medium Enterprise Agency, "2022 White Paper on Small and Medium Enterprises inJapan"
Decker, Ryan A., John C. Haltiwanger, Ron S. Jarmin and Javier Miranda. "Declining Business
Dynamism: Implications for Productivity?" (2016)
Small and Medium Enterprise Agency, "2021 White Paper on Small and Medium Enterprises inJapan"
PwC/NVCA, "MoneyTree Report"
CB Insights, "The 2020 Global CVC Report"
Mitsubishi Research Institute, "Survey Research on Management Integration between Large
Corporations and Venture Companies" (Research commissioned in 2018 by the Ministry of
Economy, Trade and Industry)
Venture Enterprise Center, "2021 Venture White Paper"
Global Entrepreneurship Monitor, "Adult Population Survey"
Venture Enterprise Center, "2021 Venture White Paper"
Yu, Sandy. (2020). "How Do Accelerators Impact the Performance of High-Technology Venture?"
Management Science, 66(2), 530-552.
"STEM fields" is a general term for the fields of Science, Technology, Engineering, andMathematics
Abbreviation for the Leaders' Forum on Promoting the Evolution of Academia for Knowledge
Society
Venture Enterprise Center, "Latest Quarterly Trend, The Fourth quarter of 2021 (October toDecember 2021" (Published March 4, 2022), and NVCA PitchBook "The Q4 2021 PitchBookNVCA Venture Monitor" (Published January 13, 2022)
Japan Finance Corporation, "2019 Survey on Entrepreneurship and Entrepreneurial Awareness."
Uchida, Hirofumi; Kwak, Charee; Hatakeda, Takashi; Honjo, Yuji; Yamori, Nobuyoshi, "Summaryof the Survey on Startup Finance in Japan" (2018)
From CB Insights "The Complete List of Unicorn Companies" (as of July 2022), with the six
companies in Japan being Preferred Networks (deep learning), SmartNews (news app), SmartHR(human resources labor software), Spiber (biomaterials), Liquid (virtual currencies), and Playco(mobile game development).
Venture Enterprise Center, "2021 Venture White Paper"

28