April 20, 2022
Press Release:

13 Institutional Investors Respond to Call for Engagement
Concern Expressed Over Japanese Companies Continuing Business in Myanmar
Mekong Watch
Friends of the Earth Japan
Justice For Myanmar
ayus:Network of Buddhists Volunteers on International Cooperation
Japan International Volunteer Center (JVC)
Network Against Japan Arms Trade (NAJAT)

On January 18, 2022, we sent a letter[*] to 125 major institutional investors holding
shares in four Japanese companies that continue to finance four problematic projects inMyanmar. The four Japanese companies are ENEOS Corporation, Sumitomo
Corporation, Marubeni Corporation, and Mitsubishi Corporation. Because the fourprojects may be financially linked to the Myanmar military, the letter asked the investors
to engage with the four companies to ensure that the companies do not provide any
revenue to the Myanmar military, which would finance its international crimes and grave
violations of human rights, including murder, persecution, arbitrary detention, sexual
violence, forced disappearance, and torture.
Following this letter, to date we have received substantive responses from 13 investors,
three of which stated that they engaged with one or more of the four companies after
receiving our letter. Further, two other investors stated that they were already engaging
with companies that were not included in our letter but regarding Myanmar.
Some European investors actively asked for further information and our view in orderto engage with the companies. On the other hand, Japanese investors, with one
exception, sent us feedback that did not correspond to our request, such as an
explanation of the investor’s human rights policy. They also did not disclose details
about their engagement with the companies, including whether they were engaging atall.
The four companies are involved in four projects in Myanmar: Thilawa Special
Economic Zone (SEZ) development, Yetagun gas project, Landmark Project (YomaCentral Project), and Thilawa Area Port Terminal Operation Project.
Regarding the Yetagun gas project, Mitsubishi Corporation and ENEOS indicatedthrough media reports after we sent our letter to investors that they are planning towithdraw from the project. However, we will continue to demand that the twocompanies take every measure to disengage from the project in a way that ensures thatfunds will not flow to the Myanmar military, and that they take responsibility for thedecommissioning of the gas field, which is expected to be depleted in the near future.
The Thilawa SEZ Management Committee has a 10% stake in the Thilawa SEZ

Development Project, and there is a possibility that a part of the dividend payments may
flow to the Myanmar military. After the attempted coup, the military arrested anddetained the chairperson of the Thilawa SEZ Management Committee and appointed anew chairperson. There are concerns that military involvement in the entire project may
increase. The Japanese government has explained that the dividend payments are notbeing made for now and that the funds are being reinvested in the project, but it isunclear how long this measure can be taken.
The land for the Landmark Project (Yoma Central Project) is subleased from thestate-run Myanma Railways. Although construction has been suspended, the military isin effective control of the Ministry of Rail Transportation which controls Myanma
Railways, and there are concerns whether it is possible to ensure that the land lease
payments do not flow to the Myanmar military.
Regarding the Thilawa Area Port Terminal Operation Project, because the militaryeffectively controls relevant government ministries, it is not possible to reliably prevent
payments under the concession contract with the Myanma Port Authority (MPA), suchas usage fees, from flowing to the military.
In Myanmar, violence and human rights violations by the Myanmar military show no signof stopping, and the number of victims of the military’s campaign of terror is increasing
by the day. We call on investors to further engage with the four Japanese companies,
and if the investee companies do not take steps to prevent the flow of revenue to theMyanmar military, to consider divestment.

* Letter sent to investors dated January 18, 2022
Japanese: http://www.mekongwatch.org/report/burma/mbusiness/20220118Letter_Jp.pdf
English: http://www.mekongwatch.org/report/burma/mbusiness/20220118Letter_Eng.pdf
The letter contained the below table.
Table: Possible flow of funds to Myanmar’s military via each project and steps requested of each company
Project name and financers (percentage ofPossible flow of funds to military
Steps requested of eachtotal funding)company
Thilawa Special Economic Zone （SEZ）
・ Possibility of partial flow of dividends ・ Suspension of dividend
Development Project1
to the military, due to 10% joint
payments
funding by the Thilawa SEZ
・ Elimination of influence
・Japanese private companies (39%)
Management Committee
from the military on
・ The military has already taken control
decision-making about● Sumitomo Corporation (32.2%)of Thilawa SEZ Management
SEZ operations● Marubeni Corporation (32.2%)
Committee personnel (the chairman ・ Withdrawal from
● Mitsubishi Corporation (32.2%)
was arrested and detained after theproject if benefiting the● Mizuho Bank (1.13%)
coup d’état, and a new chairman wasmilitary cannot be● Sumitomo Mitsui Banking Corporation(1.13%)
subsequently appointed by theavoidedmilitary), and military involvement in● MUFG Bank (1.13%)
・Japan International Cooperation Agency (JICA)
the entire project may increase(10%)
・Myanmar Thilawa SEZ Holdings (41%)
・Thilawa SEZ Management Committee (10%)
・ Suspend all payments toYetagun Gas Project2
・ The military is already in effective
military-controlled

・Petronas Carigali (40.9%)
・Myanma Oil and Gas Enterprise (MOGE)(20.5%)
・PTT Exploration and Production (PTTEP)(19.3%）
・Nippon Oil Exploration (19.3%)● JX Nippon Oil & Gas Exploration
Corporation (which is 100% subsidiaryof ENEOS) (40%)● Mitsubishi Corporation (10%)● Minister of Economy, Trade andIndustry, Japan (50%)
Landmark Project (Yoma Central Project)3・・・Special Purpose Company formed by Japaneseparticipants● Mitsubishi Corporation● Mitsubishi Estate● Japan Overseas Infrastructure
Investment Corporation for Transport& Urban Development (JOIN)
・Serge Pun & Associates’ SPA Group・Asia Development Bank (ADB)・International Finance Corporation (IFC)
Thilawa Area Port Terminal Operation Project5
・・Special Purpose Company formed by Japaneseparticipants (35%)● Sumitomo Corporation (36%)● Toyota Tsusho Corporation (34%)● Japan Overseas Infrastructure
Investment Corporation for Transport& Urban Development (JOIN) (30%)
・Kamigumi (51%)
・EFR Group (14%)

Contact:
Mekong Watch
3F Aoki Bldg., Taito 1-12-11,Taito-ku, Tokyo 110-0016, Japan
Phone: +81-3-3832-5034
E-mail: contact(@)mekongwatch.org

control of relevant government
ministries, Central Bank, and theMyanma Oil and Gas Enterprise・(MOGE), and it is not possible toreliably prevent revenue payments,
including profits from MOGE’s
investment in natural gas fields andtransmission pipelines, from being
used by the Myanmar military
It is not possible to reliably prevent
payments levied on natural gas
production and transmission basedon production sharing agreements,etc.from flowing to the military
Because the military is already in・effective control of relevant
government ministries, and land forthe project is sub-leased from
Myanma Railways under the Ministryof Rail Transportation4, it is notpossible to reliably prevent theseland lease payments from flowing to
the military

entities, holding them ina protected account until
democracy is established.

Because the military is already in・
effective control of relevant
government ministries, it is notpossible to reliably prevent payments
under the concession contract with
the Myanma Port Authority (MPA)
such as usage fees from flowing to
the military

Suspend all payments tomilitary-controlled
entities, holding them ina protected account until
democracy isestablished., since the・Withdrawal fromproject if benefiting themilitary cannot be
avoidedInvestigation ofwhether land lease
payments and otherproject returns benefit
the military, andwithdrawal if benefiting
the military cannot be
avoidedmilitary has placed MPA
under effective control
by the regime
Withdrawal fromproject if benefiting themilitary cannot be
avoided