SPARX Asset Management

Fiduciary Duty

The following is an English translation of the original Japanese version.
If there is any inconsistency between the two versions, the Japanese version shall prevail.

Regarding Our Principles on Customer-Oriented Business Conduct

SPARX was founded "to be the most trusted and respected investment company in the world." We believe it is vital that we understand exactly what our clients are thinking and seeking in order to create and offer products that will genuinely contribute to their asset growth.
SPARX defines "customer-oriented" as the capacity to earn returns that satisfy our investors. To achieve this goal, we thoroughly conduct research on our investments to ensure that we can deliver our clients high returns over the long term, while controlling the risks.
At SPARX, all officers and employees execute this principles aiming to fulfill our customer-oriented business conduct for every investor who has entrusted us with their assets, whether directly or indirectly. We cultivate high levels of professionalism and ethical standards. We make investments according to our principles with integrity and honesty in the best interests of our clients. SPARX also strives to manage and visualize our achievement of this principles by using KPIs, which we will periodically disclose.

  • Pursuing the best interests of our clients
    SPARX seeks to maximize high-quality returns over the long term after subtracting-- fees and other costs, while accounting for the risks taken by our investors. Therefore, we always strive to do the followings:
    • Consider how attractive our investments are;
    • Approach investments with professionalism, conscientiousness, and integrity; Account for our clients' needs and consider what makes the best investment, while avoiding losses or missed opportunities for our clients over the long term;
    • Seek to control investment risk and pursue high returns by conducting thorough research on potential investments on behalf of our clients who have entrusted us with their assets, and to invest in good businesses at attractive prices;
    • Contribute to improving the value of our investments by, for instance, encouraging management through meaningful engagement;
    • Manage our assets under management for each investment strategy in an optimal way by accounting for organizational structures and market conditions; for instance, take measures, including suspending public offerings, to optimally control our assets under management;
    • Work closely with distributors with an eye on consolidating or redeeming any funds that have decreased in size and developed a high expense ratio.
  • Appropriately managing conflicts of interest
    SPARX leverages its advantages as an independent investment management company in its efforts to build and maintain an advanced governance structure. We have established a policy for managing conflicts of interest to ensure that such transactions do not cost our clients returns.
    SPARX continues to actively explore new investment areas as an investment company. New conflicts of interest may arise in our creation of new types of investment. However, in each case, we will prioritize the best interests of our clients and review our conflict of interest management policy as appropriate.
  • Approach to fees and expenses
    SPARX sets its fee rate at a level that is sufficient to entice our clients to entrust their assets to us.
    SPARX aims to offer our clients high-quality returns over the long term on a net basis, after subtracting our commissions, fees, and other expenses. We strive to inform our clients of the commissions and fees that we charge in an accessible and simple manner.
  • Providing clients with the easy-to-understand information
    SPARX endeavors to provide clients with clear, accurate information about our activities and philosophy through customer-oriented reports, our website, etc.
  • Creating financial products that suit our clients
    SPARX is committed to understanding the attributes and needs of its clients and to providing them with products that we believe will genuinely contribute to their asset growth. SPARX's fundamental investment principle focuses on the long term investment through thorough field research. Accordingly, the clients best suited to SPARX's investment philosophy are investors who wish to build wealth by investing for the long term.
    We communicate our approach to the distributors we work with and to ensure that they share it with our clients.
  • Establishing our Customer-Oriented Business Conduct
    SPARX places training and education at the core of its management. We take a three-part approach to fostering the awareness all our officers and employees must have while excusing the customer-oriented business conduct: developing conscientious professionals with high levels of integrity, sharing the significance of putting the principles into practice, and furthering their understanding of the principles.
    When evaluating the performance of executives and employees, we ask for their clear commitment to the implementation of the principles. We also require all our officers and employees to fulfill our customer-oriented business conduct in line with the highest standards of trust and accountability.
    All departments in charge will regularly report to the board of directors on their achievements of the principles.