BA Partners LLC hereby announces that it has established the following Stewardship Code, effective June 22, 2026, in accordance with the “Principles on the Fiduciary Responsibilities of Institutional Investors” enacted and published by the Stewardship Code Council of the Korea Institute of Corporate Governance and Sustainability.

Principle 1. Institutional investors, as fiduciaries managing and operating the assets of others such as clients and beneficiaries, should establish and publicly disclose a clear policy to faithfully fulfill their responsibilities.

As a fiduciary, the Company exercises the duty of care of a prudent manager that puts investors’ interests first, and faithfully performs its duties in accordance with applicable laws and regulations, fund agreements and articles of incorporation, and the Company’s internal rules and procedures.

To minimize investment and management risks and ensure stability, the Company has established risk management regulations and pursues comprehensive risk management, including control over investment activities and all related operations. In addition, where the Company determines that a conflict of interest may arise in managing investment assets, it will notify investors of the relevant matters and consult with them in advance, so as to faithfully fulfill its fiduciary responsibilities and ensure that investors’ interests are not harmed.

Through regular monitoring of portfolio companies, the Company identifies key management agendas and provides advice on matters such as exercising voting rights at general shareholders’ meetings and communicating with management, thereby pursuing the enhancement of company value and sustainable growth and maximizing investors’ mid- to long-term interests.

Principle 2. Institutional investors should establish and publicly disclose an effective and clear policy on how to resolve conflicts of interest they actually face or may face in fulfilling their fiduciary responsibilities.

The Company has established internal control standards to prevent conflicts of interest between the Company and investors and between particular investors and other investors, reviews the possibility of conflicts of interest, and manages them appropriately in accordance with set methods and procedures. In addition, the Company has a compliance officer who checks and supervises compliance with the internal control standards, minimizing the possibility of conflicts of interest.

Where the Company determines that a conflict of interest may arise in the course of fulfilling its fiduciary responsibilities, it will notify investors of the relevant matters and consult with them in advance, so as to faithfully fulfill its fiduciary responsibilities and ensure that investors’ interests are not harmed.

Principle 3. Institutional investors should regularly monitor investee companies so as to preserve and increase the value of investment assets by enhancing the mid- to long-term value of investee companies.

To promote the value enhancement and sustainable growth of portfolio companies, the Company visits them monthly to discuss key issues with management, and conducts quarterly company-wide portfolio reviews to check on the status of each portfolio company.

The Company registers its investment professionals as directors of portfolio companies to participate in major decision-making through real-time monitoring, and provides a range of financial support utilizing the capital markets, such as follow-on funding and IPOs, as well as non-financial support such as industry partnership connections, HR support, and exploration of M&A opportunities, thereby pursuing the enhancement of company value and sustainable growth and maximizing investors’ mid- to long-term interests.

Principle 4. Institutional investors should aim to build consensus with investee companies, but where necessary, should establish internal guidelines on the timing, procedures, and methods of activities for fulfilling their fiduciary responsibilities.

The Company aims to enhance the mid- to long-term value of portfolio companies and strives to build consensus with them on key financial and non-financial management matters, based on its policies on investment and fiduciary responsibilities.

In the course of active shareholder engagement, the Company complies with the provisions of the Financial Investment Services and Capital Markets Act prohibiting the use of material non-public information, and will not seek trading gains based on an informational advantage derived from internal information that materially affects company value.

Principle 5. Institutional investors should establish and publicly disclose a voting policy, including guidelines, procedures, and detailed criteria for faithfully exercising voting rights, and should disclose the specific details of how they exercised their voting rights together with the reasons, so that the appropriateness of their voting can be assessed.

For all voting shares held by its funds, the Company decides whether to vote for or against each matter based on sufficient information gathering and analysis, in-depth review of the company concerned, and the results of dialogue and engagement, and exercises its voting rights accordingly, holding prior discussions with the company where necessary. In addition, the Company reports its voting records and related issues to the funds and investors in accordance with established procedures.

As a principle, the Company exercises its voting rights with priority on enhancing the mid- to long-term value of portfolio companies and on investors’ interests, and strives to secure the internal resources, organizational structure, and professional capabilities necessary to exercise voting rights faithfully.

Principle 6. Institutional investors should regularly report to clients and beneficiaries on their voting and fiduciary activities.

As a principle, the Company prepares quarterly reports on its fiduciary activities, including the status of portfolio companies, the progress of post-investment management, and voting records, and reports them to investors.

In addition, as a principle, the Company holds regular and extraordinary general meetings to report to investors and obtain their approval on the status of fund management and on material matters that arise.

Principle 7. Institutional investors should have the capabilities and expertise necessary to actively and effectively fulfill their fiduciary responsibilities.

The Company is composed of partners with diverse experience in investment, the IT industry, consulting, and finance, as well as expertise in venture capital investment. To strengthen expertise in each investment industry and to faithfully fulfill its fiduciary responsibilities, the Company also supports participation in job-related training programs and industry seminars.

To keep pace with the rapidly changing investment environment, the Company has established a performance-based compensation system that encourages its investment professionals to continue maintaining and developing their expertise and capabilities, and to give their utmost to their fiduciary activities.

Officer in charge: Soohyup Chun, Managing Director (02-567-0406, schun@bapvc.com)
Contact person: Minseok Choi, Investment Manager (02-567-0406, mschoi@bapvc.com)