Governance Initiatives (G)



In recognition of the importance of governance stipulated in the ESG policy, SPI and the Asset Management Company stipulate the following with regard to governance.

Management System of the Asset Management Company

Organizational Chart

Organizational Chart

Decision-Making Flow on Transactions with Interested Parties

The Asset Management Company stipulates rules on transactions with affiliated companies, etc.

Investment Division and
Asset Management Division
Checking legal compliance
Review and approval
Checking legal compliance
Review and approval
Board of Directors

Basic Policy on Compliance Risk Management

 In due recognition of the societal expectations for responsible business conduct, SPI and the Asset Management Company position the establishment of a compliance structure as a matter of top priority of management for compliance with various relevant laws and regulations such as the Financial Instruments and Exchange Act, various regulations stipulated by the Investment Trusts Association of Japan as well as internal rules and for carrying out business honestly and adequately.

 The Board of Directors of SPI is comprised of one executive director and two supervising directors. For the supervisory directors, one lawyer and one public accountant are appointed as outside experts. This structure allows for sufficient operation of supervisory and checking functions. The Board of Directors meeting is convened about once a month. Resolution of the agenda to be discussed follows substantial debate on the matters. Accurate and speedy delivery of required information in reports on the status of business affairs by the supervising directors to the executive director is sought through care given to materials, etc.

For details, please see “Report on Management Structure, Etc. of the Issuer of Real Estate Investment Trust Units, Etc.

Moreover, the Starts Group to which the Asset Management Company belongs is engaged in enhancing BCP measures in preparation for the occurrence of major natural disasters and other emergency situations.


  • Review of disaster response manual
  • Introduction of safety confirmation system for employees and their families
  • Stockpiling of emergency goods (three-day supply of beverage, food, simple blankets, etc.)
  • Review of in-house stockpile such as portable toilets, blankets, etc
  • Introduction of vehicles able to supply power during emergencies (part of company-owned vehicles)

Periodic In-House Compliance Training

 SPI holds compliance training for all employees once every year.

Periodic Internal Audits

 The compliance officer of the Asset Management Company verifies whether operations are in line with laws and regulations and rules as well as that they are appropriately and effectively executed, reports the results to the President and makes recommendations for improvement to the inspected organizations and divisions.

 In principle, the inspection is conducted at least once a year wherein the compliance officer submits a report to the President and the President reports to the Board of Directors.

Information Security

 The Starts Group to which the Asset Management Company belongs has formulated the Information Security Charter (seven articles) and the Information Security Bylaws (63 items) which specifically detail matters to be noted when actually handling information. Within the Group, notifications and in-office bulletins are used to remind employees of these matters in an effort to increase information security within the Group as a whole.

Same-Boat Investment

 SPI receives same-boat investment from the sponsor, Starts Corporation Inc., in order to match the interests of its unitholders with that of the sponsor.