Executive Summary

Korea's Stewardship Code in numbers

The numbers in the columns show a code that has grown in reach, while the tools to check what it achieves are only now being built.

Original: "Seeking a 'reasonable balance' in the Stewardship Code," Etoday, December 31, 2025

The first column opens with the Parable of the Talents. Before leaving, a master entrusts his property to his servants, and on his return he asks how they managed it. The two who grew the money are praised; the one who buried it is rebuked and loses even what he was given. Kim reads three elements of stewardship in the story: the one who entrusts asks for an account, holds the steward responsible for results, and then reduces, withdraws or increases the assets entrusted.

A stewardship code asks the same of institutional investors. Institutions holding clients' money should act as faithful stewards and engage actively for the long-term value of the companies they invest in. When a problem arises at a company, doing nothing or staying silent is itself a breach of that responsibility. The Korean government is also pushing to revitalize the code, with the aim of raising the value of investee companies and of the capital market as a whole.

Kim compares Korea with the United Kingdom and Japan. In the UK the financial regulator has led the code, and in Japan the Government Pension Investment Fund (GPIF), the world's second-largest pension fund with about 2,300 trillion won under management, has led it; both countries have revised their codes several times. Korea has not revised its code once since 2016. Signatories have grown to 249, but no one has checked whether they actually carried out stewardship activities or whether those activities worked. In his diagnosis, the code's effectiveness depends on how far regulators and public pension funds take the lead, whether the code keeps being monitored and revised, and how rigorously compliance is checked.

Original: "Shall minority shareholders join forces for Value-Up?" Etoday, February 24, 2026

The second column explains the reform package for the code that Korean authorities announced together at the end of 2025. Its aim is to make the code effective and bring it up to global standards. The biggest change is a timetable that gradually widens who is subject to compliance checks and stronger disclosure.

The checks look at whether each institution actually carried out the 12 activities under the code's 7 principles. Signatories can no longer stop at adopting and disclosing a policy; they must carry out matching activities and disclose the results every year. Kim expects this to have a sizable effect on companies with outside investors and on the capital market as a whole.

The "minority shareholders joining forces" in the title refers to collective engagement. The UK and Japan actively encourage investors to engage together to cut the resources and costs of engagement and improve its results. If Korea's large-shareholding disclosure rules are reformed to match advanced markets, institutions will be able to voice views on shareholder meeting agendas or specific issues jointly. As Kim puts it, minority shareholders who once said they had no power to speak up could at any moment start saying, let's pool our strength for corporate value.

There are two ways to run compliance checks. One lets the market police itself, in keeping with the code's nature as soft law; the other has the regulator supervise compliance directly and make it mandatory. Both are being discussed in Korea. In February 2026, a bill amending the Act on Corporate Governance of Financial Companies was introduced that would let the Financial Supervisory Service supervise compliance every year. Kim grants that self-regulation lightens the burden on the market and can absorb a range of best practices, but argues that it only works if checks backed by strong capital, such as those of pension funds, actually operate in the market.

Original: "Value-Up should go beyond plans to 'strategy'," Etoday, June 23, 2026 (Diagnosis and Proposal)

The third column starts from the Korea Exchange's 2026 white paper on the corporate value-up program. Value-up plan disclosures, fully launched in May 2024, have spread quickly. Companies began diagnosing their position and setting targets around shareholder returns, capital efficiency and growth, and shareholder returns such as cash dividends and share buybacks and cancellations were the most visible change. As value-up indices and related products have grown, they have started to shape market benchmarks and capital allocation.

Kim warns, however, that more disclosure does not by itself raise corporate value. What matters is not the quantity of disclosures but the quality of strategy. He borrows a distinction from the strategist Roger Martin. A plan is a to-do list of budgets, assigned tasks and progress checks. A strategy is an integrated set of choices to reach a desired result, including what not to do. If activities do not connect and do not add up to a value-creation logic the market finds convincing, they remain a plan.

The Japanese exemplars he cites are not the companies that raised dividends or buybacks the most. They are companies whose boards keep reviewing the cost of capital, reshape the business portfolio, set clear capital allocation principles and refine how they talk to shareholders. The models were not the companies with the most plans but the ones that built a system the market could trust.

So Kim offers questions a listed company should ask itself before publishing a value-up plan.

Many companies still trade below a price-to-book ratio (PBR) of 1, meaning the market values them below their book net assets, which is evidence that the Korean market's discount has not been resolved. For Kim, Value-Up is not a disclosure obligation but a strategic question the capital market puts to companies. For listed companies it is a task for closing the discount; for institutional investors it is a language for finding companies with large untapped value.

Original: "The Stewardship Code enters an era of proof," Etoday, October 7, 2026

The fourth column argues that Korea's Stewardship Code has entered a new stage. Where participation used to be what mattered, what matters now is what an investor actually did, what changed, and how convincingly it can show this. Kim points to the National Pension Service as the signal. It used to score external asset managers with extra points for adopting the code, having guidelines or publishing responsible-investment reports; now it plans to assess their stewardship activities qualitatively and tie the results to future allocations or withdrawals of funds. Stewardship is becoming part of investment capability rather than a job for the ESG team.

Japan's GPIF is already a step ahead. Rather than counting meetings with companies, it asks whether engagement fit the investment strategy, whether it had goals and milestones, and whether the company's behavior or decisions actually changed. Kim proposes presenting engagement as a story rather than a count: what issue was found, what the dialogue aimed for, how the company responded and what changed afterward, told as one value story. In his words, ten cases with clear goals, follow-up and results show a manager's capability better than a hundred company meetings.

To that end he calls for "financializing" stewardship: explaining, in the language of corporate value, how governance and ESG issues affect revenue, costs, capital expenditure, risk, capital allocation and the cost of capital, and how that feeds into corporate value and investment decisions.

Demanding more of asset managers alone will not make the system work, he adds. He lists four tasks for a new stewardship ecosystem.

This section is not a summary of the columns but an editorial by the Pebblous Data Communication Team. It is not Kim's argument.

In Kim's framing, Commercial Act reform that moves companies is one pillar, and stewardship reform that moves institutional investors is the other. Read side by side, the four columns written over ten months show where that second pillar is heading. The first sets the principle that those entrusted must account; the second turns that account into a compliance-check regime; the third applies the same logic to corporate value-up; and the fourth raises the bar for the account to evidence. The question moves from "did you join, did you disclose" to "what did you do, and what changed."

5.1The scale of proof is beyond human hands

Evidence comes from records. If no one kept track of when an issue was spotted, who discussed what with whom, and how the company responded, a value story becomes a narrative assembled after the fact. Yet the system the columns describe multiplies the records. Compliance checks will reach securities firms and banks by 2028, and every institution will disclose the results of 12 activities under 7 principles each year. As passive funds and ETFs grow, a single asset manager may have to vote at hundreds of companies. Reading every investee's disclosures and meeting agendas, logging engagement and then weaving the results into a convincing account is more than people alone can handle.

What Kim calls "financializing" stewardship, translating governance and ESG issues into the language of revenue, costs and the cost of capital, is ultimately data work: joining scattered disclosures, financials and engagement records and explaining how they relate. The corporate side is no different. A board cannot review its business portfolio against the cost of capital without numbers it can trust. We believe next-generation corporate governance will work this way, with AI helping to read, connect and explain.

5.2AI-built evidence is only as good as its data

But evidence assembled by AI is only as trustworthy as the data beneath it. Figures of unknown origin, misread disclosures and ESG scores built on different standards turn a value story into a plausible wrong answer. For a fiduciary to prove something to its client, or a company to the market, it must show not only the conclusion but where the underlying data came from and how it was handled. Proving stewardship leads to the same question as proving data.

All four are guest columns by Kim Ho-jun, CEO of Ditto ESG, in the opinion pages of Etoday. The full Korean texts are available on Etoday.

• 1.Kim, Ho-jun. (2025). "[기고] 스튜어드십코드 '합리적 균형' 찾길" (Seeking a 'reasonable balance' in the Stewardship Code). Etoday, 2025-12-31.
• 2.Kim, Ho-jun. (2026). "[기고] "밸류업 위해 소액주주 연대할까요"" (Shall minority shareholders join forces for Value-Up?). Etoday, 2026-02-24.
• 3.Kim, Ho-jun. (2026). "[진단과 제언] 밸류업, 계획 넘어 '전략'으로 추진해야" (Value-Up should go beyond plans to 'strategy'). Etoday, 2026-06-23.
• 4.Kim, Ho-jun. (2026). "[기고] 스튜어드십코드, 이제 증명의 시대로" (The Stewardship Code enters an era of proof). Etoday, 2026-10-07.