This document sets out the approach by William Blair Investment Management, LLC and William Blair International, Ltd (collectively “William Blair”) to responsible ownership with regard to the guidelines set out in the Japan Stewardship Revision Code (the “Code”) published by the Financial Services Agency (FSA) in March 2020.

William Blair delivers active investment management to private clients, institutions, and intermediaries. As well as management within funds, William Blair uses active asset allocation in managed portfolios to meet clients' diverse needs. Our funds and strategies cover a broad range of asset classes. We have a duty to act in the best interests of our clients and to seek to protect and enhance the economic value of our clients’ investments.

Institutional investors should have a clear policy regarding how they fulfill their stewardship responsibilities, and publicly disclose it.

Institutional investors should have a clear policy regarding how they manage conflicts of interest in fulfilling their stewardship responsibilities and publicly disclose it.

Institutional investors should monitor investee companies so they can appropriately fulfill their stewardship responsibilities with an orientation towards the sustainable growth of the companies.

Institutional investors should seek to arrive at an understanding in common with investee companies and work to solve problems through constructive engagement with investee companies.

Institutional investors should have a clear policy on voting and disclosure of voting activity. The policy on voting should not be comprised only of a mechanical checklist; it should be designed to contribute to sustainable growth of investee companies.

Institutional investors in principle should report periodically on how they fulfill their stewardship responsibilities, including their voting responsibilities, to their clients and beneficiaries.

To contribute positively to the sustainable growth of investee companies, institutional investors should develop skills and resources needed to appropriately engage with the companies and make proper judgments in fulfilling their stewardship activities based on in-depth knowledge of the investee companies and their business environment, and consideration of sustainability consistent with their investment management strategies.

Service providers for institutional investors should endeavor to contribute to the enhancement of the functions of the entire investment chain by appropriately providing services for institutional investors to fulfill their stewardship responsibilities.

Japan's Stewardship Code Adherence Statement (Japanese)

Japan's Stewardship Code Adherence Statement (English)