Corporate Governance Reform in Japan
Japan Corporate Governance Forum

金融庁
Financial Services Agency, the Japanese Government

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Contents

I.

Action Program for Accelerating Corporate Governance Reform

II. Encouraging the management with an awareness of profit-making andgrowthIII. Encouraging the management with an awareness of sustainability issues

IV. Resolving legal issues

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Japan Corporate Governance Forum To accelerate and strengthen corporate governance reforms, JFSA established the Japan Corporate Governance
Forum (hereinafter the “JCGF”) to hear a wide range of opinions from stakeholders, including overseas investors.
 In JCGF, while some praised the improvements in corporate governance, the following issues were pointed out: (1)management issues, such as encouraging management with an awareness of profit-making and growth based on
the cost of capital and promoting initiatives relating to sustainability, including human capital; (2) issues related tothe effectiveness of independent directors; and (3) issues related to dialogues between companies and investors.
Prime Minister Kishida’s Remarks at the New York Stock
Exchange (NYSE) September 22, 2022

JCGF event history

One very important policy is corporate governance reform. […]We will accelerate and further strengthen corporate governancereforms in Japan, such as establishing a forum in the near
future to hear from investors from around the world.

・ 1st Forum (September 27, 2022) and 4th Forum (May 25,2023) with Asian Corporate Governance Association
・ 2nd Forum (October 3, 2022) and 6th Forum (June 21, 2023)
with International Corporate Governance Network
・ 3rd Forum (January 12, 2023) and 5th Forum (June 12, 2023)
with U.S. investors, etc.

General• Corporate governance reform, including corporate mindset, has begun to make substantial progress. Although
there are still some issues, we look forward to further progress.

M a i n o p i n i on s i n J C G F

Issues related to
management andeffectiveness of
independent
directors• The importance of capital efficiency is being recognized, but it is not recognized by all companies. Issues include
accumulation of cash, low ROE, and a large number of companies with PBR below 1.
• Board diversity, including gender perspective, and disclosure on human capital are needed.
• Effectiveness of independent directors, such as strengthening the roles of the nomination / remuneration committee
and ensuring the independence of the board are needed.

Issues related todialogue
betweencompanies andinvestors• Fiduciary responsibilities in index investment have not been fully fulfilled, and it is necessary to improve the treatment ofinvestment personnel.
• It is necessary to enhance disclosure, such as submission of Annual Securities Reports prior to general shareholders
meetings.
• It would be useful to enhance English disclosure and make visible companies with good corporate governance.
• It is necessary to review the legal system from the perspective of promoting and substantiating engagement andprotecting minority shareholders.
• There are concerns that listed subsidiaries may harm the interests of minority shareholders and that there is a large-2number of cross-shareholdings.

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Action Program for Accelerating Corporate Governance Reform The Council of Experts Concerning the Follow-up of Japan’s Stewardship Code and Japan’s Corporate Governance
Code published recommendations regarding "Action Program" as of April 26. The Council will review the
implementation status from time to time and consider whether additional measures are needed.
Action Program for Accelerating Corporate Governance Reform: From Form to SubstanceApproach to f uture initiative•
It is vital to move the f ocus of ref orm f rom f orm to substance in resolving the issues. To this end, it is necessary tocreate an environment that promotes self -motivated changes in the mindsets of companies and investors, as well as
to make the dialogues between companies and investors more productive and more ef f ective.
•
It is appropriate to examine the timing of the revision of each Code in a timely manner based on the status ofprogress f rom the viewpoint of the ef f ective implementation of corporate governance ref orm, not necessarily f ollowing
the review cycle in the past years.

１．Issues for seeking sustainable corporate growth andincreased corporate value over the mid- to long-term
Cooperate
appropriately

ListedCompanies
Management
Mid- to long-term
issues

Effective
Oversight

Current issues

SupportRisk-taking

I s s ue sProfit-making
and growth
based on costof capital

Stakeholder otherthan shareholders

Board
Out
side

Nominationcommittee

Initiatives onsustainability,
including humancapital

Out
side

・・・

Remunerationcommittee

Effectiveness of
independent
directors

Specific measuresA) Encouraging the management with an awareness of profitmaking and growth
Encourage the management with an awareness of prof itmaking and growth based on the cost of capital (such as theproper allocation of management resources toward risk taking , including a business portf olio review and investments
in human capital, intellectual properties and R&D )B) Encouraging the management with an awareness ofsustainability issues
Encourage companies to take actions on sustainabilit ythrough publication of companies’ good disclosure practices.
Consider measures to improve the diversity of the board andcore human resources, such as increasing the percentage off emale executives (target of 30% or more by 2030).
C) Improving the effectiveness of independent directors
Promote f urther improvement of the ef f ectiveness of
independent directors through compilation and publication of
the actual status and examples of a board, nominationcommittee and remuneration committee, and educational
activities to promote understanding of the roles expected ofindependent directors-3-

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Action Program (cont.)
Action Program for Accelerating Corporate Governance Reform: From Form to Substance

2. Issues related to dialogue between companies and investors

Proxyadvisors

Listed companies

ReturnProvideRecommendation

Constructive dialogues
based onthe mid- to long- term view

Enhancing thedisclosure
Promoting dialogues
with global investors

Investment

LegalissuesSpecific measuresA) Effective implementation of stewardship activities

Investors（shareholders）
ReturnPromote the ef f orts of asset managers and asset owners todeal with the issues relating to the stewardship activities(including allocating suf f icient resources, providing
incentives f or stewardship activities, establishinggovernance structures of asset owners).

B) Enhancing the disclosure as a basis for dialogue

Asset
manager

Asset
owner

Investment

Effective implementation of
stewardship activities

Request to disclose the status of dialogues and make clear
suf f icient and insuf f icient cases of “Explain”.
Consider measures to provide investors with the inf ormation
they need prior to the general shareholder meeting and topromote timely disclosure of corporate inf ormation.

C) Promoting dialogues with global investors
Promote dialogues between companies and global investors
by “visualizing” companies that willingly and actively respondto the expectations of global investors and f urther expand
the coverage of English disclosure.

D) Resolving legal issues
Consider clarif ication of "act of making importantsuggestions" and "joint holders" under the large shareholding
reporting rule, transparency of benef icial shareholders, andhow to protect minority shareholders in the case of a partial
takeover bid.

E) Resolving market environment issues
Consider the disclosure and corporate governance issues
with regard to quasi-controlled listed companies, f ollow up
on the progress of reduction of cross -shareholdings andconsider whether f urther measures are called f or.
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Prime Minister Kishida's Remarks to the Economic Club of New York (September 21, 2023)[…] we will reform the asset management sector as well as asset ownership, which will manage the expanding funds.
The funds managed in the Japanese asset management sector have skyrocketed by 50% during the last three years,
and now stand at 800 trillion yen. We will push hard to encourage sophisticated asset management and to solicit new
entrants. To start with, we will rectify Japan's unique business practices and resolve barriers to entry, and will also
introduce a new program to assist new entrants. We will also promote deregulation to enable asset management firms
to outsource their back-office operations.
To encourage new entry from overseas, we will establish special business zones tailored specifically for asset
management business where administrative procedure can be completed solely in English. In these zones, we willtake measures to improve the business and living environment tailored to needs of overseas asset managers. To
ensure that our reforms reflect the needs of global investors, I will launch an asset management forum consisting of
U.S. and Japan institutions as core members, including those of you participating today.
In parallel, we will strengthen the effectiveness of corporate governance reforms. We will systematically follow
up the developments to encourage management to place importance on price book-value ratio (PBR), as wellas to promote formulation, disclosure, and implementation of their business reform plans.
The vision I spoke today will be put in concrete action as a policy package. To garner support for this vision, we willhold a “Japan Weeks” event this autumn, and invite investors around the world. I would be delighted if you would join
us in this endeavor.
I met a globally influential investor the other day who said to me, "You know Mr. Prime Minister, I've been watching theJapanese economy every year for 30 years, and I have never seen it more positive than it is now." I would urge you toevaluate what we are doing in my country, look at the underlying strength of our economy and our plans for the future
and then invest in Japan. […](Reference) Prime Minister Kishida's Remarks to the Economic Club of New York, Ministry of Foreign Affairs of Japan

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Ⅱ

Contents

I.

Action Program for Accelerating Corporate Governance Reform

II. Encouraging the management with an awareness of profit-making andgrowthIII. Encouraging the management with an awareness of sustainability issues

IV. Resolving legal issues

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Ⅱ

Request for “Action to Implement Management that is Conscious of
Cost of Capital and Stock Price”

 TSE issued notices to all companies listed on the Prime and Standard Market which requested as follows in March.
Requested Action
 In order to implement management that is conscious of cost of capital and stock price, please implement thefollowing series of actions on an ongoing basis.

Analysis of Current
Situation• Gain a proper understanding of the company's cost of capital and profitability• Analyze and evaluate the current situation around these and the market valuation at board of
directors meetings

Planning &Disclosure• Have board of directors discuss and develop policies, targets, planning periods, and specificinitiatives for improvement• Disclose clear information on these, along with assessment of the current situation, to investors

Implementation of
Initiatives• Push forward with management that is conscious of cost of capital and stock price, based on thedisclosed plans• Engage in proactive dialogue with investors based on this disclosure

Conduct a progress analysis and update disclosures at least once a year

Start Date
 Since analysis and discussion of the current situation must be carried out sufficiently before planning and disclosure
can begin, TSE is not specifying a timeframe for the start date of disclosure, but requests as prompt a response as
possible.
Note: If it takes some time to analyze and discuss the current situation, disclosure could be expanded in stages, for example by firstindicating the level of progress of plan development and preparation for disclosure and the expected timing of disclosure, and thendisclosing specific details once the plan is developed.
(Source) Excerpts from “Action to Implement Management that is Conscious of Cost of Capital and Stock Price” Tokyo Stock Exchange, Inc., partially processed by FSA

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Status of Disclosure on “Action to Implement Managementthat is Conscious of Cost of Capital and Stock Price”

Material of Council of Experts
Concerning the Follow-up of Market
Restructuring (The Eleventh Council
on August 29, 2023), Tokyo Stock
Exchange, Inc.

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Ⅱ

Disclosure Status by PBR and Market Cap. Levels(Prime Market)

Material of Council of Experts
Concerning the Follow-up of Market
Restructuring (The Eleventh Council
on August 29, 2023), Tokyo Stock
Exchange, Inc.

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Follow-up From TSE(Source) Excerpts from Material of Council of Experts Concerning the Follow-up of Market Restructuring (The Eleventh Council on August 29, 2023), Tokyo Stock Exchange, Inc., partially processed by FSA- 10 -

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Contents

I.

Action Program for Accelerating Corporate Governance Reform

II. Encouraging the management with an awareness of profit-making andgrowthIII. Encouraging the management with an awareness of sustainability issues

IV. Resolving legal issues- 11 -

Ⅲ

Improve the diversity of the board and core human resources- Increase the percentage of female executives

 The government of Japan set the targets for the ratio of female executives in Prime Market-listedcompanies.
 TSE aims to implement the revisions to Listing Rules by October 2023.
Excerpt of the Intensive Policy for Gender Equality and the Empowerment of Women 2023
(1) Setting numerical targets for the ratio of female executives at companies listed on the Prime Market, etc.
As an important and symbolic first step to accelerate the promotion of women in the corporate sector, numericaltargets for the ratio of female executives in Prime Market-listed companies will be set to increase the ratio of female
executives.
Promote initiatives to include the following provisions in exchanges’ regulations by the end of 2023:-

Each company listed on the Prime Market shall strive to appoint at least one female executive by 2025-

Each company listed on the Prime Market shall aim to raise the ratio of female executives to 30% or more by 2030-

Each company listed on the Prime Market is recommended to formulate its action plan to achieve theaforementioned goals.

Additionally, based on the Action Program for Accelerating Corporate Governance Reform, the Cabinet Office and the
Financial Services Agency will explore additional measures, depending on company progress, to increase diversity on
boards and in core human resources including the increase in the ratio of female executives.

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Ⅳ

Contents

I.

Action Program for Accelerating Corporate Governance Reform

II. Encouraging the management with an awareness of profit-making andgrowthIII. Encouraging the management with an awareness of sustainability issues

IV. Resolving legal issues- 13 -

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Overview of the Tender Offer Rule

 The tender offer rule forces a tender offer for the following transactions, and requires (i) prior information disclosureand (ii) equal treatment of shareholders in order to ensure the "transparency and fairness" of securities transactions
that may have an impact on corporate control.
Voting rights ratio after transaction
Over 5%Off-market trades(more than 10 persons
in 60 days)

Off-market trades

Over 1 / 3Majority

2 / 3 or more

5%rule1 / 3 Rule
(A tender offer is required.
Partial tender offer is allowed.)

2 / 3 rule(Partial tender offer is
not allowed)

Exemptions(up to 10 persons
in 60 days)

Market trades

In principle, not subject to rules.

 The main regulations on the implementation of a tender offer are as follows:
Disclosure
regulations

 The offeror must disclose the volume to be purchased, the tender offer price and tender offer period
in advance.
 The target company must disclose the opinion with respect to the tender offer.

Other
regulations

 A minimum tender offer period of 20 business days (a maximum of 60 business days) must be set.
 The tender offer price shall be the same for all shareholders.
 During the tender offer period, the offeror must not purchase shares other than through a tender offer.
 The offeror must not change the terms and conditions to the disadvantage of shareholders.
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Main issues to consider

 It has been pointed out that (i) transactions in which more than 1 / 3 of the voting rights are acquired throughmarket trades should also be subject to tender offer rule and (ii) the scope of the partial tender offer should
be limited because the partial tender offer could be coercive.
Voting rights ratio after transaction
Over 5%Off-market trades

Over 1 / 3Majority

2 / 3 or more

5%rule1 / 3 Rule
(A tender offer is required.
Partial tender offer is allowed.)(more than 10 persons
in 60 days)

Off-market trades

2 / 3 rule(Partial tender offer is
not allowed)

Exemptions(up to 10 persons
in 60 days)

Market trades

In principle, not subject to rules.
Japan

Europe Transactions in which more than 1 / 3 of thevoting rights are acquired through market
trades are not subject to tender offer rule.

 Regardless of the type of transaction, atender offer is required when a certain
threshold is exceeded.

 Partial tender offer is allowed if the ratio ofvoting rights after the tender offer isless than 2 / 3.

 In principle, partial tender offer is not allowed.

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Main issue (1): Market trades It has been pointed out that market trades should be subject to the tender offer rule (1/3 rule).
Comments on the Current Rule
 The current tender offer rule does not apply to a market trade unless it falls under so-called “rapid accumulation,"
given that a certain degree of transparency and fairness is ensured.

 On the other hand, recently, there have been cases of acquiring more than 1/3 of the voting rights through market
trades. In such transactions, it has been pointed out that general shareholders are not given sufficient information
or time necessary for investment decisions and that there are issues of coercion (see the decision of the Tokyo High Court
below). Therefore, it has been pointed out that market trades should be subject to the tender offer rule (1/3 rule).
Tokyo High Court, decision of November 9, 2021

“The appellants purchased shares whose ownership ratio of share certificates exceeds 1/3 in a short period of timethrough acquisition of shares on market trades that is not subject to the tender offer rule. Such purchase does notprovide general shareholders with sufficient information and time necessary for investment decisions and tends to makegeneral shareholders take actions to avoid such risks if they think that the corporate value of the company may bedamaged by the acquisition of control by the purchaser. Therefore, such purchase is recognized to have an incentive tosell or pressure to sell (coercion) for general shareholders.”

Issues to be discussed What is your view on making transactions for acquiring more than 1/3 of the voting rights through market
trades subject to the tender offer rule?
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Main issue (2): Measures against Coercive Tender Offer It has been pointed out that certain measures should be taken against a coercive tender offer.
Comments on the Current Rule
 In the case of a tender offer that is expected to reduce the corporate value of the target company after theacquisition of control, there is a problem in that general shareholders have an incentive to apply for the tender offer
in order to avoid disadvantages due to the reduction in corporate value (so-called coercive tender offer). There is arisk that general shareholders may be forced to accept the tender offer price at an unreasonably low price, and that
acquisitions that reduce corporate value will tend to be more successful. It has also been pointed out that theserisks are more likely to occur in a partial tender offer (tender offer with an upper limit) than in a tender offer without
an upper limit. (Note).
 In order to address the issue of the coercive tender offer, the following measures could be taken with reference tothe Takeover Code in the UK.
Measures to eliminate or reduce the risk of coercionI

A measure to lower the threshold (currently 2/3) at which a partial offer is allowed.

II

A measure that requires an additional tender offer period after the tender offer is successful.

III

A measure that allows the implementation of the partial tender offer only when shareholders with a majority of the voting rights
approve it.

Issues to be discussed What is your view on the implementation of measures to address the issue of coercive tender offer and thecontent of such specific measures?
(Note) In the case of a tender offer without an upper limit, since the tender offeror must purchase all the tendered shares, in order to make it economically viable for the tender offeror, the tender offer pricemust be set lower (compared to the case of a partial tender offer), and it has been pointed out that it is likely to be possible for each shareholder to choose not to tender predicting that other shareholders will
also not subscribe.

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Overview of the large shareholding reporting rule

 The large shareholding reporting rule requires large shareholders to disclose the status of shareholdings in order toimprove the transparency and fairness of the market by promptly providing the information.
 This rule is divided into “general reporting,” which is a basic disclosure type (cf. Regulation 13D in US), and“special reporting,” which allows special measures for institutional investors (cf. Regulation 13G in US).
General Reporting

Obligations of
Large
Shareholders

1. If an investor becomes a large shareholder (more than a 5% stake):- The investor must submit a large shareholding report within five business days of acquiring more than a 5%
in a company.
2. If there are any significant changes, such as a 1% or greater increase/decrease in the percentage ofshareholdings following the submission of the large shareholding report:- The investor must submit a “change report” within five business days of the change.

Special Reporting

Outline of theSpecialReportingRule

The rule allows institutional investors who repeatedly and continuously execute buy/sell transactions of shares in their
daily operations to report under relaxed frequency of submissions.
<Details of the relaxation>
Only to submit a “large shareholding report” and “change report” within five business days of the preregistered reference date set twice a month.
<Eligibility to use special reporting>
1. The investor’s ownership ratio does not exceed 10%.
2. The investor is not committing to the Act of Material Proposal.
3. It is necessary to register the reference date to the authority.

Joint Holders

Treatment of
Joint Holders

A shareholder is required to calculate its shareholding ratio by including the shareholding of a person that
corresponds to any one of the following (“Joint Holder”).
1. A person that has agreed to obtain or assign shares in cooperation with the shareholder.
2. A person that has agreed with the shareholder to jointly exercise voting rights and other shareholder rights.
3. A person that has a special relationship with the shareholder, such as a certain capital relationship or a family
relationship.

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Main issues to consider

 From the viewpoint of promoting effective engagement with companies by investors, it has been pointed out that thescope of "material proposal" should be limited or clarified.
 It has been pointed out that the scope of "joint holders" should be limited or clarified from the viewpoint ofpromoting collective or collaborative engagement.
General Reporting

Obligations of
Large
Shareholders

1. If an investor becomes a large shareholder (more than a 5% stake):- The investor must submit a large shareholding report within five business days of acquiring more than a 5% in acompany.
2. If there are any significant changes such as a 1% or greater increase/decrease in the percentage of shareholdings
following the submission of the large shareholding report :- The investor must submit a change report within five business days of the change.

Special Reporting

Outline of theSpecialReportingRule

The rule allows institutional investors who repeatedly and continuously execute buy/sell transactions of shares in their
daily operations to report under relaxed frequency of submissions.
<Details of the relaxation>
Only to submit a “large shareholding report” and “change report” within five business days of the pre-registeredreference date set twice a month.
<Eligibility to use special reporting>
1. The investor’s ownership ratio does not exceed 10%.
2. The investor is not committing to the Act of Material Proposal.
3. It is necessary to register the reference date to the authority.

Joint Holders

Treatment of
Joint Holders

A shareholder is required to calculate its shareholding ratio by including the shareholding of a person that corresponds
to any one of the following (“Joint Holder”) .
1. A person that has agreed to obtain or assign shares in cooperation with the shareholder
2. A person that has agreed with the shareholder to jointly exercise voting rights and other shareholder rights.
3. A person that has a special relationship with the shareholder, such as a certain capital relationship or a family
relationship.
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Main issue (1): Scope of the Act of Material Proposal

 It has been pointed out that the scope of "the act of material proposal" is unclear so that it becomes an obstacle toeffective engagement between companies and investors.
Comments on the Current Rule
 Under the large shareholding reporting rule, a special reporting rule has been established for institutional investors
to ease the frequency of submission. However, in order to be eligible for the rule, it is necessary that the purposeof shareholding is not to engage in "the act of a material proposal" to investee companies.
 Although the interpretation of "the act of material proposal" was clarified when formulating the Stewardship Code, it
has been pointed out that further clarification is necessary in order to promote effective engagement.

Guideline published in 2014

Main issues to be addressed

1 Request explanation of management policies.
2

Explanation for a specific planfor exercising voting rights

3

Request for an explanationof the stance given on ②

4

Ask questions at
a general shareholders meeting

5
6

Request for resolution of specific mattersat a general shareholders meeting
Request changes in business policies

May not be
considered“Material Proposal“This arrangement has become a certain interpretation guideline.
However, the following points are raised.
May be considered“Material Proposal”

The subject of the material proposal is comprehensive and as
the proposal relates to capital policy or business strategy,
it may be regarded as a material proposal.
Issues can only be communicated indirectly through inquiries
with the company, and proposals cannot be communicateddirectly, so the company cannot understand the intention.

Issues to be discussed What is your view on limiting or clarifying the scope of "the act of material proposal" in order to promote
effective dialogue between companies and investors?
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Main issue (2): Scope of the Joint Holders

 It has been pointed out that the scope of "joint holders" is so unclear that it becomes an obstacle to collective or
collaborative engagement.

Comments on the Current Rule
 Under the large
shareholding
reporting rule, shareholders are required to calculate their shareholding ratio
material
proposal Actions
including the shareholdings of "joint holders."
 At the time of formulating the Stewardship Code, the interpretation of "joint holders" was clarified. However, in lightof the recent increase in collective or collaborative engagements, it has been pointed out that the scope of "joint
holders" needs to be further clarified.

Guideline published in 2014
In principle, the following cases may not be considered "joint
holders":

The agreement between an investor and another investor
remains within the scope of shareholders’ general activities
that are unrelated to the exercise of legal rights.

In the situation where an investor in discussions with anotherinvestor communicates their plan for the exercise of voting
rights and finds that the plan is the same as the other investor.

Main issues to be addressed
This arrangement has become a certain interpretation guideline.
However, the following points are pointed out.


There is a concern that if an investor who participated in thecollective or collaborative engagement submits a shareholder
proposal, and then the other investor agrees to it, the otherinvestor may be considered as a "joint holder";The concept of "joint exercise of voting rights" can be read asa very comprehensive regulation, with no limitations on the
purpose of controlling management.

Issues to be discussed
 Given that it has been pointed out that the interpretation of "joint holder" is unclear when conducting collective or
collaborative engagements, what is your view on limiting or clarifying the scope of "joint holders"?
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Transparency of beneficial shareholders

 It has been pointed out that the transparency of beneficial shareholders should be improved with reference tosystems in other countries in order to promote dialogue between companies and investors.
(*)The term "Beneficial shareholder" here means a person who is not a shareholder on the shareholder register (nominee shareholder)but who has the authority to give instructions on voting right and investment.
Japan As for nominee shareholders, there is a system for companies and other shareholders to identify throughshareholder register or disclosure of major shareholders in annual securities reports.
 On the other hand, as for beneficial shareholders, there is no system for companies or other shareholders
to identify unless they are subject to the large shareholding reporting rule (more than 5%).
Systems in other countries

USUK An institutional investment manager that exercises investment discretion over $100 million or more insecurities that trade on a national securities exchange must report details of its holdings including the nameof the issuer and class, the CUSIP number, the number of shares and the total market value quarterly on
Form 13F with SEC. Form 13F fillings are publicly disclosed on EDGAR database.
 A public company may give notice to any person whom the company knows or has reasonable cause tobelieve to be interested in the company's shares with voting rights issued to confirm the fact.
 Those who received such notice are required to confirm whether or not it is the case, and if he or she holds
or has held any such interest, to give further information including the information enough to identify persons
interested in the shares in question and the number of shares within such reasonable time as may be
specified in the notice.

Issues to be discussed What is your view on the necessity and content of measures to enable the company and other shareholders
to effectively identify beneficial shareholders?
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Thank you for your attention.
We hear from you at
jcgf.secretariat@fsa.go.jp

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