Korea Stewardship Code 7 Principles

• Institutional investors, as a steward of assets entrusted by their clients, beneficiaries, etc, to take care of and manage, should formulate and publicly disclose a clear policy to faithfully implement their responsibilities.

  ANDA Asset Management’s financial analysts are trained in the incorporation of ESG issues and we support the Code by engaging with management and actively advising on and participating in proxy voting. These responsibilities are incorporated into our investment process and summarized in our Policy. Our Policy is available here.

• Institutional investors should formulate and publicly disclose an effective and clear policy as to how to resolve actual or potential problems arising from conflicts of interest in the course of their stewardship activities.

  We have outlined our approach to managing conflicts of interest in ANDA’s Compliance Manual and ANDA’s Proxy Voting Policies, which are summarized in Part 2A of ANDA’s Form ADV. ANDA recognizes that there may be times when meeting agendas or proposals create a material conflict of interest or the appearance of a material conflict of interest. ANDA constantly strives to adhere to best industry practice to avoid conflicts of interest and to take these into consideration in the implementation of its management, investment and compliance policies.

• Institutional investors should regularly monitor investee companies in order to enhance investee companies’ mid- to long-term value and thereby protect and raise their investment value.

  ANDA takes an active approach in addressing corporate governance in fulfilling its fiduciary duties. Our analysts and portfolio managers regularly monitor the companies in which we invest by focusing on alignment of interests between the investee company’s management and shareholders. Continuous comprehensive research and engagement with investee companies are important characteristics of our investment philosophy. ANDA considers a variety of resources including company reports and press releases, third-party research, and independent proxy voting advisor reports and recommendations.

• While institutional investors should aim to form a consensus with investee companies, where necessary, they should formulate internal guidelines on the timeline, procedures, and methods for stewardship activities.

  ANDA seeks to engage constructively with investee companies to ensure that they are pursuing the strategies and processes that reflect the best interest of shareholders. We conduct ongoing monitoring and aim to help promote long term sustainable growth. Additionally, we seek to enhance corporate governance at investee companies through proxy voting.

• Institutional investors should formulate and publicly disclose a voting policy that includes guidelines, procedures, and detailed standards for exercising votes in a faithful manner, and publicly disclose voting records and the reasons for each vote so as to allow the verification of the appropriateness of their voting activities.

  ANDA seeks to discharge its responsibilities under the Korea Stewardship Code by means of the implementation of a clearly defined voting policy, which is available here. We endeavor to take all reasonable steps to vote proxies in the best interests of clients, applying prevailing best practices, codes and standards of corporate governance. We disclose our voting activity to the extent required by the applicable regulatory authorities and provide our clients periodic updates on our voting activities as required in the respective client agreements or upon client request.

• Institutional investors should regularly report their voting and stewardship activities to their clients or beneficiaries.

  We keep records of our proxy voting activity. We disclose our voting activity as detailed in our statement regarding Principle 5, above. We also provide our clients periodic updates on our voting activities as required in the respective client agreements. Our 2022 Proxy Voting and Company Engagement Report is available here.

• Institutional investors should have the capabilities and expertise required to implement stewardship responsibilities in an active and effective manner.

  ANDA’s investment team endeavors to develop an in-depth knowledge of investee companies. ANDA uses many external resources to deepen its knowledge of business and governance practices at investee companies, including daily market news, proxy voting research and external corporate governance sources. ANDA’s management team, comprised of its senior officers including certain portfolio managers, ultimately oversees the firm’s governance activities.