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Stewardship Code
Principles on the Stewardship Responsibilities of Institutional Investors
  • I. Declaration of Participation in the Stewardship Code
    BNB Asset Management Co., Ltd. (the “Company”) accepts and participates in the implementation of the Korea Stewardship Code, “Principles on the Stewardship Responsibilities
    of Institutional Investors,” enacted and announced by the Stewardship Code Enactment Committee of the Korea Institute of Corporate Governance and Sustainability (KCGS).
    As a fiduciary that manages and operates the assets of its clients and investors, the Company faithfully fulfills its responsibilities, thereby pursuing the enhancement of the medium- to long-term
    value and sustainable growth of investee companies, and ultimately seeking the medium- to long-term interests of its clients and beneficiaries.
    Through this implementation policy, the Company discloses its implementation plans for the seven detailed principles of the Stewardship Code, and will faithfully fulfill these principles in
    accordance with the “Comply or Explain” approach.
  • II. Implementation Plans by Principle
    1. Institutional investors, as fiduciaries managing and operating the assets of others such as clients and beneficiaries,
      must establish and disclose a clear policy to faithfully fulfill their responsibilities.
      [Implementation Plan]
      • The Company places investors' interests above the interests of the Company and its officers and employees.
      • The Company treats the interests of all investors equally and does not favor or discriminate against any particular investor without reasonable grounds.
      • The Company faithfully fulfills its duty of care as a prudent manager in accordance with relevant laws and regulations, fund agreements, and internal regulations.
      • The Company discloses this policy through its website and other channels.
      • The Company discloses its management philosophy, corporate history, and founding background through its website.
    2. In the course of fulfilling its responsibilities as a fiduciary, an institutional investor must establish and disclose an effective
      and clear policy on how to resolve conflicts of interest that it actually faces or may potentially face.
      [Implementation Plan]
      • To resolve conflicts of interest that may arise in the course of fulfilling its stewardship responsibilities, the Company establishes and complies with internal control standards
        and conflict-of-interest prevention regulations.
      • The Company appoints a Compliance Officer independent of the investment division to continuously review and supervise the potential for conflicts of interest.
      • Where the possibility of a conflict of interest is recognized, the Company notifies the relevant investor in advance and proceeds with the transaction only after taking the necessary
        measures to ensure there is no issue with investor protection.
      • The Company discloses this conflict-of-interest prevention policy through its website and other channels.
      • The Company operates information barriers (Chinese Walls) between departments to fundamentally and structurally block the possibility of conflicts of interest.
      • To raise awareness of the importance of conflict-of-interest prevention, the Company conducts related training for its officers and employees at least once a year.
    3. Institutional investors must periodically monitor investee companies so as to enhance their medium- to long-term value and thereby preserve
      and increase the value of the invested assets.
      [Implementation Plan]
      • The Company establishes and operates an internal system for periodically monitoring the financial matters of investee companies.
      • Where the monitoring results are deemed necessary to enhance the medium- to long-term value of an investee company, the Company may carry out additional engagement activities.
      • Periodic monitoring may be conducted through various means, including company visits, review of disclosure materials, and use of research reports.
    4. While aiming to build consensus with investee companies, institutional investors must, where necessary, establish internal guidelines on the timing, procedures,
      and methods for carrying out activities to fulfill their stewardship responsibilities.
      [Implementation Plan]
      • The Company establishes internal guidelines on the timing, procedures, and methods of its stewardship activities and carries out its activities accordingly.
      • In the course of its stewardship activities, the Company strictly complies with relevant laws and regulations, including the FSCMA provisions prohibiting the use of undisclosed
        material information, and does not seek improper gains by using the inside information of investee companies.
    5. Institutional investors must establish and disclose a voting policy that includes guidelines, procedures, and detailed criteria for the faithful exercise of voting rights,
      and must also disclose the specific details of, and reasons for, their voting so that the appropriateness of the exercise can be assessed.
      [Implementation Plan]
      • The Company adopts as a basic principle that voting rights are exercised with the interests of investors as the foremost priority.
      • The Company may establish and disclose “Voting Guidelines” setting out the criteria and procedures for exercising voting rights.
      • The Company records and manages its voting records and may report them to investors upon request.
      • The Company establishes and operates guidelines on the exercise of voting rights and may, where necessary, refer to the opinions of external proxy advisory firms.
        However, the final decision rests with the Company's own responsibility and judgment.
    6. Institutional investors must periodically report to their clients and beneficiaries on their voting and stewardship activities.
      [Implementation Plan]
      • The Company records and manages its voting records and the status of its stewardship activities.
      • The Company may report the status of its stewardship activities to investors at least once a year.
      • However, where necessary, the Company may keep certain information undisclosed, taking into account the impact that disclosure of such information may have on investors' interests
        and corporate value.
      • As a general private fund, the Company is not obligated to make public disclosures; nevertheless, it may report to investors and endeavors to maintain the transparency of its stewardship
        activities to the greatest extent possible.
    7. Institutional investors must possess the capabilities and expertise necessary to actively and effectively fulfill their stewardship responsibilities.
      [Implementation Plan]
      • The Company designates the specialized personnel (those in charge) necessary to fulfill its stewardship responsibilities and specifies the responsible persons and persons in charge in its documentation (including names and contact information).
      • The Company establishes and operates an independent compliance organization, including a Compliance Officer and a Compliance Team.
  • III. Persons Responsible for and in Charge of the Stewardship Policy, Implementation, and Disclosure
    Category Name Department/Title Phone Email
    Responsible Person Lee Heung-il Compliance Officer/
    General Manager    		 02-786-5329 hilee@bnbasset.com
    Person in Charge Min Sung-gi Compliance Team/
    General Manager    		 02-786-5366 sgmin@bnbasset.com
    Download BNB Asset Management Stewardship Code
    Effective Date: June 22, 2026 BNB Asset Management Co., Ltd.