KO

Stewardship Code

SL Investment adopts the "Principles on the Fiduciary Responsibilities of Institutional Investors" established by the Korea Corporate Governance Service (KCGS), and has implemented its own Stewardship Code effective January 24, 2022.

Principle 1. Clear Establishment and Disclosure of Fiduciary Responsibility Policy
  • SL Investment was incorporated on February 3, 2000, and is registered as a small and medium enterprise venture capital company under the Small and Medium Enterprise Startup Support Act.
  • Pursuant to the Act on the Promotion of Venture Investment, the Company forms and manages venture investment funds using assets entrusted by external investors.
  • As a fiduciary, the Company will comply with applicable laws, fund agreements, and internal regulations, and will faithfully discharge its fiduciary duties in the interests of investors.
  • The Company will pursue the medium- and long-term interests of clients and beneficiaries through active engagement and shareholder activities aimed at enhancing the value and growth of portfolio companies.
Principle 2. Establishment and Implementation of Conflict of Interest Prevention Policy
  • The Company recognizes that conflicts of interest may arise among investors, portfolio companies, affiliates, and employees.
  • The Company establishes and efficiently operates internal control standards to minimize conflicts of interest, and provides employee training.
  • Matters of potential conflict of interest are referred to the Compliance Officer in advance for proper handling.
  • When a conflict of interest arises, the Company notifies investors and takes measures to protect investor interests.
Principle 3. Periodic Monitoring of Portfolio Companies
  • The Company reviews both financial factors (financial structure, business performance) and non-financial factors (management strategy, governance, shareholder policies, etc.).
  • Disclosure of information and periodic and ad hoc reporting are made mandatory through investment agreements.
  • The Company conducts continuous monitoring and actively participates in general meetings, board meetings, and investor conferences.
  • The Company regularly evaluates and manages invested assets to maintain thorough oversight and soundness.
Principle 4. Engagement with Portfolio Companies and Establishment of Internal Guidelines
  • The Company maintains active dialogue with the management of portfolio companies and provides management advisory support.
  • The Company shares its expertise and network to support portfolio growth.
  • Investment agreements include provisions for resolving legal and contractual violations.
  • Post-investment management regulations are established with clearly defined scope, procedures, and criteria.
Principle 5. Establishment and Disclosure of Voting Rights Policy
  • Key general meeting agenda items are reported to investors and their approval is obtained through investment agreements.
  • Voting rights are exercised after thorough review by the investment team and review by the CEO and Compliance Officer.
  • The Company prioritizes the creation of long-term shareholder value by exercising voting rights that reflect shareholder rights protection, equality, social responsibility, and management transparency.
  • Voting records are reported to fund partners through general meetings and reporting systems.
  • Given the private fund structure, detailed voting records are not disclosed publicly in order to prevent competitive harm.
Principle 6. Reporting on Exercise of Voting Rights and Fiduciary Activities
  • The Company reports on fund management status and key matters at least once a year through general meetings, semi-annual meetings, and investor conferences.
  • The Company obtains approval from investors regarding management activities.
  • Fiduciary responsibilities are fulfilled through extraordinary general meetings and ad hoc reporting.
  • Records of voting rights exercise and fiduciary activities are maintained.
  • Reporting obligations under fund agreements and articles of association are fulfilled.
Principle 7. Building Capacity and Expertise to Fulfill Fiduciary Responsibilities
  • The Company employs a diverse range of specialists for fund management roles.
  • Professional development is supported through job-related training and domestic and international seminars and forums.
  • Experienced professionals are assigned to the risk management and compliance functions.
  • A competitive performance system is operated to attract and retain talent.
  • Professional training programs for employees are supported.
Contact: Eun-Sook Hwang, Director (02-6241-5400, eshwang@slinvestment.com)