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Sumitomo Mitsui Trust Asset Management

PRI reporting framework 2017

You are in Strategy and Governance » Investment policy

Investment policy

SG 01. RI policy and coverage (Not Completed)

SG 02. Publicly available RI policy or guidance documents

New selection options have been added to this indicator. Please review your prefilled responses carefully.

02.1. Indicate which of your investment policy documents (if any) are publicly available. Provide a URL and an attachment of the document.





02.4. Additional information [Optional].

SG 03. Conflicts of interest

03.1. Indicate if your organisation has a policy on managing potential conflicts of interest in the investment process.

03.2. Describe your policy on managing potential conflicts of interest in the investment process.

 We introduced measures such as the clarification of internal rules and guidelines that prohibit the exercise of influence when there are concerns over conflicts of interest in any of its asset management departments. Furthermore, we established measures to increase the effectiveness of such rules by establishing an internal reporting system for its asset management operations, as well as improving company guidance on action to be taken when problematic conduct is discovered. The bank strives to thoroughly enforce these rules by providing training for all officers and employees, requiring each employee to sign a pledge to uphold the rules. Concerning our stewardship activities, we make (1) detailed public disclosure regarding the standards for the exercising of voting rights (“Guidelines for Exercise of Voting Rights” )and (2) the introduction of new operations based on reports issued by the Stewardship Activity Advisory Committee. The majority of the Committee’s members are comprised of external personnel, including the bank’s external director, an attorney, and an emeritus professor in corporate governance. To monitor these activities, Fiduciary Risk Management Department with the fiduciary business as well as Compliance Department and Risk Management Department at the bank level.. 

03.3. Additional information. [Optional]


Sumitomo Mitsui Trust Bank’s clients have extremely high expectations for the bank in regards to the performance of fiduciary duties and stewardship responsibilities as a responsible investor. The bank is constantly looking for new ways to develop and strengthen its conflict of interest management structure, increasing transparency so that clients may enter into transactions with ever greater peace of mind. Below is an introduction to the latest developments in its approach to fiduciary responsibilities, in particular its improved measures against conflicts of interest, as an indicator of the progress made within the financial industry in Japan as a whole.  

  To date the bank has leveraged its significant expertise and comprehensive capabilities to conduct asset management operations in order to maximize returns for beneficiaries based on the “Fiduciary Spirit” it has adhered to since its founding. In recent times, with the increasing specialization and complexity of financial services, a variety of conflict of interest risks have arisen – between both business divisions within the company and between in-group companies. As such, and also from the standpoint of “Fiduciary Spirit”, the bank believes that it is necessary to take more comprehensive steps to prevent situations in which the interests of clients may be unfairly impaired.  

  Increased scrutiny of fiduciary responsibilities coincides with current capital market reforms in Japan, where companies are encouraged to be transparent and actively engage with stakeholders through the introduction of the Stewardship Code and the Corporate Governance Code. As the bank acts as an investment manager, it is held accountable for its investment activities by disclosing its engagements and proxy voting actions publicly. To do so, the bank has strengthened its framework of fiduciary responsibilities, and built up its conflict of interest management structure. All the bank’s officers and employees recognize the importance of the practical implementation of stewardship responsibilities and fiduciary duties, and having built an appropriate structure the bank acts transparently and faithfully in carrying out its operations as it seeks to maximize returns for its beneficiaries.

SG 04. Identifying incidents occurring within portfolios (Private)