ESG Policy

1.　Purpose

As a venture capital firm, we have a fiduciary responsibility to our beneficiaries. We recognize that we have a social responsibility to realize a sustainable society, increase in corporate value, and sound development of capital markets.
Therefore, we believe that appropriate consideration of environmental, social, and corporate governance (hereinafter collectively referred to as "ESG") issues in each investment process is essential to achieving our vision to create new industries to solve global issues of humankind, by bringing capital, talent and knowledge, around science and technology. We believe that this will not only help us to achieve our vision and long-term return on investment, but also fulfill our social responsibilities. We hereby set forth the following policy.

2.　Scope of Application

This policy shall apply to all investment activities in all funds managed by us.

3.　Policy

We shall give due consideration to the following factors in the process of deal sourcing, investment decision-making, post-investment monitoring and voting, and Exit.

1. Environment: air and water pollution, ecosystem diversity, climate change, deforestation, ecosystem services, hazardous substances, land degradation, resource depletion, waste management, water scarcity, etc.
2. Social: Data protection and privacy, equal opportunity, government and local community relations, human rights, indigenous rights, labor standards (freedom of association and collective bargaining, occupational health and safety, living wage, standards against child labor and forced labor), labor management relations, standards against product mis-selling, product safety and liability, initiatives to promote the advancement of women, etc.
3. Corporate governance: accounting standards, anti-competitive behavior, appropriate auditing systems, standards against bribery and corruption, corporate ethics, compliance (including fines and other sanctions), executive compensation, lobbying, political contributions, risk management, internal reporting systems, etc.

4.　Implementation

The Company will commit to develop and implement ESG-related measures with adherence to this policy.

5.　Engagement

We will work together to encourage acceptance and implementation of ESG initiatives within the venture capital industry and strive to enhance their effectiveness.

6.　Reporting

We require our portfolio companies to disclose appropriate ESG-related information and report to investors on the status and progress of activities related to this policy.

7.　Modification

We will periodically review this policy and amend it as necessary to reflect widely held ESG standards. This policy may be changed only by a resolution of the Board of Directors. However, minor changes, including revisions to terminology, may be made by resolution of Managing Partner, CEO and President.

We signed the United Nations Principles for Responsible Investment (PRI) in April 2022.

Privacy Policy

The University of Tokyo Edge Capital Partners Co., Ltd. (the “Company”) hereby establishes this policy regarding the handling of personal information (this “Privacy Policy”) as follows. The definitions of terms used herein will be governed by the Act on the Protection of Personal Information (the “Personal Information Protection Act”) and relevant laws and regulations.

1.　Compliance with Relevant Laws, Regulations, Guidelines, Etc.

The Company will comply with the Personal Information Protection Act, other relevant laws and regulations, guidelines, etc., established by the Personal Information Protection Commission, and this Privacy Policy, and handle personal information in a lawful and appropriate manner.

2.　Acquisition of Personal Information

When the Company acquires personal information in connection with its business, it will acquire such personal information in a lawful and appropriate manner.

3.　Purpose of Use of Personal Information

The Company will use the personal information acquired in connection with its business within the scope of the following purposes of use, or within the scope of the purposes of use that are clear from the circumstances of the acquisition, and will not use it for any other purpose, except with the consent of the person concerned or as permitted by laws or regulations.

1. Establishment and management of a fund and any businesses related or incidental thereto
   • To provide information on the fund and services related thereto;
   • To confirm the identity of investors;
   • To report to investors the management status and other matters of the fund;
   • To sell or otherwise dispose of securities, etc., held by the fund; and
   • To conduct any other administrative work related to the establishment and management of the fund.
2. Venture capital investment and any businesses related or incidental thereto
   
   • To identify potential target companies for investment;
   • To plan capital and financial policies for potential target companies for investment;
   • To determine whether or not to invest, through examination and evaluation of business feasibility, technology, products, etc., of potential target companies for investment;
   • To introduce and implement services provided by the Company or external support companies to enhance the value of, and conduct consultations for, portfolio companies, and to conduct any other administrative work related thereto; and
   • To conduct any other administrative work related to venture capital investment business.
3. Human resources introduction and any businesses related or incidental thereto
   
   • To apply for a position at, and disclose information to, companies offering employment, based on the user’s consent and agreement;
   • To provide information related to finding employment or changing jobs, and provide services related thereto;
   • To confirm the status of users during or after the provision of services, such as services for finding employment and changing jobs;
   • To confirm the status of employment of users with companies offering employment; and
   • To provide advice and proposals for recruitment planning of companies offering employment.
4. Others
   
   • To send notices, etc., related to the Company’s business;
   • To hear opinions and requests, etc., for the purpose of improving the Company’s business;
   • To hold, operate, manage, and provide information on, services, exhibitions, seminars and other events;
   • To respond to inquiries, consultations and complaints to the Company, and to settle disputes with the Company;
   • For recruitment activities of the Company; and
   • To provide personal information to the Company’s affiliated companies within the scope of the purposes of use above.

4.　Entrustment of Personal Data

The Company may entrust the handling of personal data to its subcontractors to the extent necessary to achieve the purposes of use. Provided, however, that the personal data which is entrusted will be limited to the minimum information necessary to perform the entrusted business.

5.　Provision of Personal Data to Third Parties

The Company will not provide personal data to third parties (excluding subcontractors), except with the prior consent of the person concerned or as permitted by laws or regulations. Provided, however, that the Company may share personal data with third parties as described below:

1. Items of personal data to be shared
   Items of personal data held by the Company that are within the scope necessary to achieve the purposes of use.
2. Scope of parties who share personal data
   Affiliated companies and organizations of the Company (the University of Tokyo Edge Capital Partners Co., Ltd., UTEC Venture Partners, Inc., UTEC 3 Limited Partnership and UTEC Partners Limited Liability Partnership) and external support companies such as financial institutions that work with the Company to provide support such as enhancing the value of portfolio companies.
3. Purposes of use of parties who share personal data
   Same as the purposes of use stipulated in 3 above.
4. Person responsible for information management in sharing personal data
   Controller, the University of Tokyo Edge Capital Partners Co., Ltd.

6.　Management of Personal Data

1. Ensuring accuracy of data content
   The Company will maintain accurate and up-to-date personal data to the extent necessary to achieve the purposes of use, and will endeavor to delete such personal data when it is no longer necessary to use it.
2. Security management measures
   The Company will take necessary and appropriate measures to prevent leakage, loss or damage of personal data or otherwise manage the security thereof.
3. Supervision of employees
   When having employees handle personal data, the Company will ensure that it will inform them of the appropriate handling of personal data, provide them with appropriate training, and supervise them as necessary and appropriate.
4. Supervision of subcontractors
   When entrusting the handling of personal data to a third party, the Company will select a subcontractor that has appropriate security management measures in place and supervise such subcontractor as necessary and appropriate.

7.　Receipt of Requests related to Personal Data Held by the Company

1. When the Company receives a request from the person concerned or his/her agent to notify the purpose of use of personal data held by the Company, the Company will notify such person without delay, except in the following cases:
   1. When, with respect to the personal data held by the Company that can identify the person concerned, the purpose of use is clear;
   2. When there is a risk of damage to the life, body, property or other rights and interests of the person concerned or a third party;
   3. When there is a risk of damage to the rights or legitimate interests of the Company; and
   4. When, with respect to necessary cooperation with a government agency or local government in the execution of legally prescribed duties, there is a risk of interference with the execution of such duties.
2. When the Company receives a request from the person concerned or his/her agent to disclose personal data held by the Company, the Company will notify such person without delay, except in the following cases:
   1. When there is a risk of damage to the life, body, property or other rights and interests of the person concerned or a third party;
   2. When there is a risk of interference with the appropriate conduct of the Company’s business; and
   3. When such notification is in violation of laws or regulations.
3. If the Company receives a request from the person concerned or his/her agent to correct, add or delete personal data held by the Company, the Company will conduct an examination without delay and take appropriate measures based on the results thereof.
4. If the Company receives a request from the person concerned or his/her agent to suspend use of or delete, or suspend provision to a third party of, the personal data held by the Company, and it is found that there is a reason for such request, the Company will take appropriate measures.
5. In the case of the requests (1) through (4) above, please send a request to the contact desk of the Company in 8 below.

8.　Contact Desk for Inquiries and Complaints

The Company has established the following contact desk for lawful and appropriate handling of personal information:
Click here

9.　Revision of Privacy Policy

The Company may review the contents of this Privacy Policy as appropriate, and may make changes as necessary. In such case, the revised Privacy Policy will be applied from the date of publication of the revised version.