Public Consultation on the Amendment to the Korea Stewardship Code

We refer to the invitation from the Korea Institute of Corporate Governance and Sustainability (KCGS) to comment on the draft amendment to the Korea Stewardship Code. We appreciate the opportunity to provide feedback as KCGS considers how to strengthen the stewardship framework for institutional investors in Korea.

Norges Bank Investment Management (NBIM) is the investment management division of the Norwegian Central Bank and is responsible for investing the Norwegian Government Pension Fund Global. NBIM is a globally diversified investment manager with USD 2.11 trillion (KRW 3,047.16 trillion) at 31 December 2025 invested across 68 countries, of which approximately USD 27.6 billion (KRW 39.9 trillion) was invested in the shares of 410 South Korean listed companies.

As a long-term, global investor, we consider our returns over time to be dependent on sustainable development in economic, environmental and social terms, as well as on well-functioning, legitimate and efficient markets. As a sovereign wealth fund, NBIM does not sign up to stewardship codes. We nonetheless recognise their important role in setting expectations for institutional investors, and we share our views in that spirit.

The proposed amendment comes amid a coordinated effort to strengthen stewardship in Korea. The amended Commercial Act extends directors' duty of loyalty to shareholders. This is complemented by the Financial Supervisory Service (FSS) 2026 Supervision and Examination Plan for the asset management industry, which puts fiduciary duty, the exercise of voting rights and investment disclosure at its centre.^[1] Under this plan, the FSS will examine asset managers' exercise of voting rights, processes to enforce shareholder rights and support KCGS to strengthen the Code. We welcome the alignment between the supervisory agenda and the Code, and we support the proposed revisions.

Several of the changes reflect positions we hold and have set out to other regulators and standard setters: the integration of material sustainability factors into stewardship; the link between engagement and investment decisions; a clearer approach to escalation; explicit room for collaborative engagement; clear expectations on the exercise and disclosure of voting; and clearer expectations of asset managers and service providers.

We set out detailed comments in the annex. We ask KCGS and the Stewardship Code Council (the Council) to consider three enhancements in particular: to require signatories to publish their stewardship reports rather than only file them with KCGS; to clarify the responsibilities and nomination processes of the Council and ensure both international and domestic investor representation; and to coordinate the Council's assessment of signatories with the FSS compliance review so that the two reinforce one another rather than overlap. We remain at your disposal should you wish to discuss any of these points.

Yours sincerely

Carine Smith Ihenacho
Chief Governance and Compliance Officer                                                   

Jeanne Stampe
Lead Policy Advisor

[1] Financial Supervisory service 2026 Supervision. Examination Plan for Capital Markets / Asset Management (25 March 2026)