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Cross-shareholdings disclosures, Japan Financial Services Agency (FSA)

Cross-shareholdings disclosures, Japan Financial Services Agency (FSA)

Mr. Akira Nozaki Director
Corporate Accounting & Disclosure Division
Policy and Markets Bureau
Financial Services Agency

27th November 2024

Dear Mr. Nozaki,

RE: Revision draft of Cabinet Ordinance of Annual Securities Report disclosure on cross-shareholding

The International Corporate Governance Network (ICGN) appreciates the opportunity to comment on the Revision draft of Cabinet Ordinance of Annual Securities Report disclosure on cross-shareholding.

Led by investors responsible for assets under management of $77 trillion, ICGN is an authority on global standards of corporate governance and investor stewardship.

Headquartered in London, our membership is based in more than 40 countries – largely in Europe and North America, with growing representation in Asia. The ICGN Global Governance Principles and Global Stewardship Principles, written from an investor perspective, are widely used by our members in their company assessments and voting decisions, and by regulators when developing corporate governance rules.

Cross shareholdings

ICGN supports the efforts of the Japanese FSA to strengthen the disclosures related to cross shareholdings.

It is very important that the nature and purpose of remaining cross-shareholdings be clearly disclosed, along with clarification of the impact on returns on capital.

Additionally, ICGN continues to recommend that companies should publicly disclose a plan to eliminate cross-shareholdings over a specified period and that progress towards achieving this should be regularly reported to shareholders.

Thank you again for the opportunity to share our perspective on this matter. If you would like to follow up with questions or comments, please contact our Japan Advisor, Amane Fujimoto (amane.fujimoto@icgn.org).

Jen Sisson
Chief Executive Officer
International Corporate Governance Network

Autumn Conference 2026

4–5 November 2026
Toronto

, 

Canada

Policy

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Draft 2026-2030 Strategic Plan Goals and Objectives, Public Company Accounting Oversight Board​
Amendments to the German Corporate Governance Code,  Regierungskommission Deutscher Corporate Governance Kodex

Cross-shareholdings disclosures, Japan Financial Services Agency (FSA)

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Cross-shareholdings disclosures, Japan Financial Services Agency (FSA)

Will Farrell

Federated Hermes
Assistant Manager, EOS
London

Will co-leads the climate change theme at EOS, the stewardship arm of Federated Hermes Limited, where his coverage includes companies in Europe and Australia, primarily financial services, energy, chemicals, and materials. Prior to joining EOS, Will worked in the energy and infrastructure investment banking team at Macquarie Capital, where he specialised in renewable energy. Before that, Will held a number of roles across the UK climate policy space, including as a parliamentary researcher for Rt. Hon. Chris Skidmore MP on climate and energy issues, and as a climate and economic policy analyst at a diplomatic institute. He was appointed as a voluntary adviser to Rt. Hon. Alok Sharma MP, President of COP26, on preparations for COP26 after co-founding a Westminster climate policy group in 2019, which engaged MPs and Members of the House of Lords to advocate for more ambition on climate action in public policy. Will has a Bachelor’s degree (1st Class Honours) in Economics from the London School of Economics and Political Science.