ICM Global Funds

Statement on its Stewardship Responsibilities under the Korea Stewardship Code

ICM Global Funds Pte Ltd (“ICMGF”) is a fund management company headquartered in Singapore, and a wholly-owned subsidiary of ICM Limited. Responsible investment is an integral part of ICMGF’s investment process, and ICMGF treats corporate governance as a core consideration when assessing investments. As a signatory to the Korea Stewardship Code, ICMGF accepts its stewardship responsibilities, which it discharges through engagement, dialogue, and monitoring of investee companies. These Principles apply to the ICMGF mandates where listed-equity voting and stewardship activities are undertaken. Set out below is how ICMGF implements each Principle of the Korean Stewardship Code.

Principle 1: Institutional investors as trustee who administer and manage the assets of their clients, beneficiaries and other parties should prepare and publicly disclose a clear policy on how they will diligently discharge their stewardship responsibilities.
 

ICMGF supports the principles of the Korea Stewardship Code and recognises its stewardship responsibilities as an institutional investor. Engagement with investee companies forms an integral part of ICMGF’s investment process and stewardship activities. ICMGF maintains a documented Responsible Investment Policy that integrates Environmental, Social and Governance (“ESG”) considerations into its investment decision-making and stewardship process, consistent with its fiduciary duty to clients and its objective of promoting sustainable long-term value creation. The Responsible Investment Policy is reviewed regularly by ICMGF’s ESG Committee and updated as necessary to reflect changes in regulatory requirements, market practice and the evolving expectations of clients and other stakeholders.  

 

Principle 2: Institutional investors should prepare and publicly disclose a robust and clear policy on addressing conflicts of interest that are faced or are likely to be faced in the course of discharging their stewardship responsibilities.
 

ICMGF recognises that actual or potential conflicts of interest may arise during its investment and stewardship activities, including engagement with investee companies and the exercise of voting rights. ICMGF is committed to conducting its business in accordance with applicable laws and regulations and the highest standards of professional and corporate ethics. ICMGF maintains a Code of Conduct and Compliance policies designed to identify, assess, manage and monitor conflicts of interest.  These policies seek to ensure that investment, engagement and voting decisions are made independently and in the best interests of clients and beneficiaries. Where a conflict of interest is identified, appropriate measures are taken to manage or mitigate the conflict in accordance with ICMGF’s established procedures. ICMGF’s conflict of interest framework is reviewed by senior management and the compliance function and is updated as necessary to reflect changes in regulatory requirements and business practices. 

Principle 3: Institutional investors should regularly monitor investee companies to enhance investee companies’ medium- to long-term value and thus protect and raise the investment value.
 

ICMGF monitors investee companies on an ongoing basis as part of its investment management and stewardship activities. As a long-term investor, ICMGF carries out ongoing research and engages regularly with company management to assess strategy, performance, corporate governance, risk management, and other matters relevant to long-term shareholder value. ICMGF does not rely solely on third-party ESG ratings or data providers. Instead, it applies its own ESG assessment framework, informed by industry standards such as those developed by the Sustainable Accounting Standards Board (“SASB”), during both the due diligence and ongoing monitoring stages of the investment process.

 

Principle 4: Institutional investors should seek to create a rapport with investee companies, and if necessary, should prepare internal guidelines on the timeline, procedures, and methods for engagement with investee companies.
 

As a long-term investor and active owner, ICMGF engages with investee companies on matters affecting shareholder interests and the long-term sustainability of the business. Where ICMGF identifies concerns regarding a company’s management, strategy, risk oversight, capital allocation or standards of corporate governance, it seeks constructive dialogue with the company management as appropriate. Engagement is generally conducted on an individual basis. However, ICMGF does not object in principle to collaborative engagement with other investors where such engagement is considered appropriate and consistent with applicable laws and regulations. Each situation is assessed on its own merits, considering the relevant facts and circumstances. Where concerns remain unresolved, ICMGF may consider escalation measure, including additional meetings with management or directors, voting against relevant resolutions, collaborative engage with others, or reducing or exiting an investment where appropriate.

Principle 5: Institutional investors should prepare and publicly disclose a voting policy that includes guidelines, procedures, and detailed standards for exercising votes in a diligent manner, and publicly disclose voting records and the reasons for each vote so as to enable reviewing the appropriateness of their voting activities.
 

ICMGF maintains a documented Voting Policy that sets out the principles, procedures and considerations applied when exercising voting rights. Each voting decision is considered individually, considering the specific circumstances of the investee company and the interests of shareholders. While ICMGF takes into account the recommendations of a company management, it supports such recommendations only where it believes they are in the best interests of shareholders and consistent with long-term value creation. ICMGF exercises its voting rights independently and does not automatically follow the recommendations of proxy advisory firms. Where ICMGF votes against management’s recommendation, the reasons for doing so are recorded.

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ICMGF’s Voting Policy is available to clients and investors upon request. Information regarding voting activities may also be provided to clients and investors where doing so does not conflict with client confidentiality obligations, legal requirements or the protection of proprietary investment strategies.

Principle 6: Institutional investors should report periodically to their clients or beneficiaries on their voting and stewardship activities.

ICMGF reports periodically to clients and investors on matters relating to portfolio management and stewardship activities, as appropriate. This Stewardship Statement is publicly available and is reviewed and updated as necessary. The most recent version, together with details of any updates, is notified to the Korea Corporate Governance Service in accordance with applicable requirements. Where appropriate and consistent with client confidentiality obligations and the protection of proprietary investment strategies, ICMGF may provide additional information regarding stewardship activities, engagement outcomes and voting activity to clients and investors.

Principle 7: Institutional investors should possess the capabilities and expertise necessary for discharging stewardship responsibilities in a proactive and effective manner.
 

ICMGF seeks to maintain the resources, expertise and governance structures necessary to discharge its stewardship responsibilities effectively. Stewardship activities are carried out by ICMGF’s investment professionals, who possess relevant sector expertise, market knowledge and investment experience, under the oversight of ICMGF’s Board and ESG Committee. ICMGF applies its own ESG assessment framework rather than relying on third-party providers and integrates stewardship considerations into its investment process. ICMGF operates from more than ten international offices and supports the advancement of responsible investment practices through its membership of the UN-supported Principles for Responsible Investment (PRI).

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Contact:

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Jack Cuddigan, ESG Manager
Phone: +44 1372 221393
Email: compliance@icm.limited

 

Jae Yoo, Representative, ICM Global Funds
Phone: +65 6466 3038
Email: compliance@icm.limited

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Last Updated: July 2026