Policy

Privacy Policy

1. Introduction

MPower Partners GP, Limited and MPower KK (collectively, the “Company”) are committed to protecting the privacy of our customers. The Company has established the following privacy policy in compliance with the Act on the Protection of Personal Information (the “Personal Information Protection Act”) and other related laws and regulations regarding the handling of personal information obtained by the Company. The Company will comply with the Personal Information Protection Act and other relevant laws and ordinances, establish the following privacy policy, and strive to handle personal information appropriately.

2. Purpose of collection and use of personal information

The Company shall request, collect, store and use the personal information provided to it for the following purposes:

  • Carrying out administrative procedures related to or in connection with the management of funds and assets;
  • Collection of information necessary for investment decisions, communication and response to inquiries;
  • Responding to inquiries and interviews about the Company;
  • Recruitment, administration and management of  human resources 
  • Ensuring effective and efficient performance and completion of other customer transactions; and 
  • Carrying out all other transactions, functions and processes related or incidental to the above.

3. Safety management measures for personal information

In order to prevent leakage, loss, or damage of the personal information we handle, we will implement necessary and appropriate measures to securely manage all personal information collected. In addition, the Company will appropriately supervise its employees and any third party to whom the Company entrusts or transfers the  personal information, to ensure that the personal information is appropriately and securely managed.

4. Provision of personal information to third parties / shared use

The Company will not provide personal information to third parties without the consent of the individual, except when required by the Personal Information Protection Act or other applicable laws and regulations. However, the Company may share the personal data collected on the  following basis:

  • Items of personal data to be shared
    • Basic information such as name, address, telephone number and e-mail address, as well as investment-related information such as the number of shares held
  • Parties who may jointly use personal data
    • MPower Partners GP, Limited
    • MPower KK
  • Purposes of use by parties jointly using the information
    • Same as the purpose of use described in 1
  • Person responsible for information management in case of joint use
    • MPower KK 

5. Consignment of business

The Company may provide personal information to subcontractors to the extent necessary to achieve the purpose of use announced or notified. In such cases, the Company will require the subcontractors to handle the personal information provided by the Company in an appropriate and secure manner and will supervise them appropriately. 

6. Contact for disclosure, correction, suspension of use, deletion, etc. of personal information

In the event that the Company receives a request or demand from an individual for disclosure, correction, addition, deletion, suspension of use, deletion, suspension of provision to a third party, or notification of the purpose of use of personal information held by the Company, the Company will respond appropriately in accordance with the Personal Information Protection Act after confirming the identity of the person making the request. 

For more information, inquiries, and consultation regarding the handling of personal information by the Company, please contact us at the details below. 

Entities handling personal information: MPower Partners GP, Limited and MPower KK

Telephone number: 03-6807-3891

Email: info@mpower-partners.com

7. Use of Cookies and Google Analytics

The Company uses cookies on the website. Cookies are used to help the Company understand how its services are being used and to help MPower improve its services. Cookies are small-text files retrieved by the site, as part of MPower’s interaction with your browser. No personally identifiable information will be captured in the cookies or transferred to a third party.

You can set your browser to restrict the use of cookies. Please note that if you restrict the use of cookies, your access to certain services and website functions may be limited. 

The Company also uses Google Analytics to understand how thewebsite is used. For more information on Google Analytics, including how the data is collected and processed, please refer to the following URLs.

https://marketingplatform.google.com/about/analytics/terms/jp/

https://www.google.com/intl/ja/policies/privacy/

https://www.google.com/intl/ja/policies/privacy/partners/

8. Changes to the Privacy Policy

The Company may periodically change this Privacy Policy as necessary.

Diversity, equity, and inclusion (DEI) at MPower

As an ESG-integrated fund, diversity, equity and inclusion (DEI) are embedded in our DNA. We believe that companies that put DEI at the top of their agenda will be more successful in the long run and we seek to partner with ventures and teams who share this perspective. 

We also believe that it is our responsibility to put this point of view at the core of all aspects of how we operate, from our investment activities, to our community and ecosystem involvement, and to how we compensate and reward our employees.

We know that progress on DEI requires both commitments and concrete actions. Here are ours:

Investment process and portfolio support

DEAL SOURCING: 

VCs continue to underinvest in female founders as well as those from other underrepresented groups. We invest in the most promising innovations and teams, irrespective of background or other personal characteristics. An expanded network is what’s needed to build a diverse, equitable, and inclusive venture ecosystem, and we aim to be leaders in this effort.

We encourage any founders of startups that provide technology-enabled solutions to societal challenges, are aligned with our fund’s ESG mission, and have already raised a first round of funding, to reach out to us. 

PORTFOLIO COMPANY DEI SUPPORT: 

Awareness of DEI as a core driver of business value has grown significantly in recent years. While there has been progress, startup ecosystems globally continue to lag on various key DEI indicators. We believe that this problem is not simply rooted in constrained resources but rather a general lack of knowledge on which concrete strategies and actions will yield the best results. 

We actively support our portfolio companies to identify ways to make their management team, boards, and employee base more diverse and their work environment more equitable and inclusive. Some examples include supporting initiatives to identify and cultivate diverse independent board members and senior management members, and providing resources for DEI training. 

Internal operations

TEAM: 

DEI continues to be a challenge for the tech industry and, particularly, venture capital. We are committed to hiring promising, diverse talent from all backgrounds to our own team. We strive to achieve this through an open, inclusive recruitment approach, while considering proven techniques such as blind interviews, public job postings, and recruiting from non-traditional networks or sources. Interested candidates can reach out to us here. 

We also seek to create a truly inclusive work environment. We take a flexible approach to work location, hours, and time off, so our employees can better balance their work and home life. 

MEASUREMENT AND TRANSPARENCY: 

As we believe that you can’t manage what you don’t measure, we have identified and regularly track metrics to support an inclusive work environment and investment strategy. We maintain the utmost confidentiality when gathering and managing the data we use to track our progress. Consequently, we only share consolidated information when sharing information publicly. 

Commitments are only the first step in building a truly diverse, equitable, and inclusive business. We believe that taking action and instilling a culture of transparency is critical. Thus, we take concrete steps to do this by ensuring that DEI features prominently in both our regular reporting to our LPs and periodic updates to the broader community. 

Ecosystem engagement

DEI IN THE VENTURE ECOSYSTEM: 

With the rising focus on DEI in recent years, VC funds around the world have stepped up their DEI pledges and financial commitments. There has been a notable increase in thematic funds led by or investing in women and other underrepresented groups. However, there continues to be a significant gender and diversity gap within our industry, particularly at the investment team level. Evidence shows that diverse teams drive stronger business results. VC is no different. 

We aim to do our part in making DEI the norm in the venture ecosystem. We are also a vocal advocate for progress on this topic via our thought leadership and in our engagements with fellow VCs in Japan and elsewhere. And, to ensure more diverse investors are brought into deals, we continue to build-out our peer network to include VC funds with diverse GPs as well as those with similar DEI ambitions and commitments to ours.

To that end, we want to ensure that the numerous venture-related events are diverse and inclusive. We will speak at conferences where the total percentage of diverse speakers (defined as women, LGBTQ+, foreigners, persons with disabilities) is at least 20%. For events that do not achieve this threshold, we are eager to support the organizers in reaching this level by helping them identify diverse speakers. 

While 20% may not seem like an ambitious target from a global perspective, the unfortunate reality is that it is still a challenge for many Japanese startup-related events. We hope to be a catalyst for change, and will work towards ensuring more diverse representation within the overall ecosystem. In addition, we plan to raise this threshold in the coming years.

EDUCATION AND AWARENESS: 

We are committed to being DEI change agents within the global venture ecosystem. We actively seek opportunities to lend our voice through public advocacy, including speaking engagements, thought leadership, and collaborations with key stakeholders. 

Finally, it is important to stress that we do not tolerate any discrimination based on gender, ethnicity, race, religion, physical resources, age, sexual identity or any other form of identity;  whether it comes from our employees, investors, or our portfolio companies. 

Anti-Social Forces Policy

MPower Partners LP has set forth, and is committed to fully complying with the following basic policy to prevent and eliminate any relationship with any organizations influenced by or comprised of organized crime (“Anti-social Forces”).

(1) Organizational response

MPower shall maintain a firm stance to respond, as an organization, to any inappropriate demands from suspected and actual Anti-social Forces. The Company will ensure the safety of our officers and employees who might be exposed to or have to deal with such demands from Anti-social Forces in the discharge and fulfilment of their employment responsibilities.

(2) Zero tolerance with Anti-social Forces

MPower Partners shall implement a zero-tolerance policy that rejects any relationship, including business relations, with suspected and actual Anti-social Forces. MPower shall neither have nor maintain relationships with any Anti-social forces whatsoever.

MPower shall reject any demands from Anti-social Forces and shall not conduct or participate in any transactions involving or provide funds to suspected or actual Anti-social Forces, taking immediate and appropriate legal measures in the event that it receives any demands made by suspected or actual Anti-social Forces.

(4) Prevention of Anti-social activities 

MPower shall take appropriate measures to prevent anti-social criminal activities and protect its employees against any unreasonable demands made by Anti-social Forces.

(5) Cooperation with specialized organizations

The Company shall strive to establish a close, collaborative and on-going relationship with local law enforcement authorities, attorneys and other external specialized regulatory authorities/organizations.

ANTI-HARASSMENT POLICY 

All Unlawful Harassment Prohibited 

MPOWER strictly prohibits and does not tolerate unlawful harassment against employees or any other  covered persons, including interns, because of race, religion, creed, national origin, ancestry, sex (including  pregnancy), gender (including sexual orientation, gender identity, and status as a transgender or transsexual  individual), age, physical or mental disability, citizenship, genetic information, or any other characteristic  protected under applicable law.  

Sexual Harassment 

All MPOWER Persons are prohibited from harassing employees and other covered persons based on that  individual’s sex or gender (including pregnancy, sexual orientation, gender identity, and status as a  transgender or transsexual individual) and regardless of the harasser’s sex or gender.  

Sexual harassment means any harassment based on someone’s sex or gender. It includes harassment that is  not sexual in nature (for example, offensive remarks about an individual’s sex or gender), as well as any  unwelcome sexual advances or requests for sexual favors or any other conduct of a sexual nature, when any  of the following is true: 

• Submission to the advance, request, or conduct is made either explicitly or implicitly a term or condition  of employment. 

• Submission to or rejection of the advance, request, or conduct is used as a basis for employment  decisions. 

• Such advances, requests, or conduct have the purpose or effect of substantially or unreasonably  interfering with an employee’s work performance by creating an intimidating, hostile, or offensive work  environment. 

MPOWER will not tolerate any form of sexual harassment, regardless of whether it is: 

• Verbal (for example, epithets, derogatory statements, slurs, sexually related comments or jokes,  unwelcome sexual advances, or requests for sexual favors). 

• Physical (for example, assault or inappropriate physical contact). 

• Visual (for example, displaying sexually suggestive posters, cartoons, or drawings, sending inappropriate  adult-themed gifts, leering, or making sexual gestures). 

• Online (for example, derogatory statements or sexually suggestive postings in any social media platform  including Facebook, Twitter, Instagram, Snapchat, etc.). 

This list is illustrative only and not exhaustive. No form of sexual harassment will be tolerated. Harassment is prohibited both at the workplace and at employer-sponsored events.

Other Types of Harassment 

MPOWER’s anti-harassment policy applies equally to harassment based on an employee’s race, religion, creed,  national origin, ancestry, age, physical or mental disability, citizenship, genetic information, or any other  characteristic protected under applicable law.  

Such harassment often takes a similar form to sexual harassment and includes harassment that is: 

• Verbal (for example, epithets, derogatory statements, slurs, derogatory comments, or jokes). 

• Physical (for example, assault or inappropriate physical contact). 

• Visual (for example, displaying derogatory posters, cartoons, or drawings or making derogatory  gestures). 

• Online (for example, derogatory statements or sexually suggestive postings in any social media platform  including Facebook, Twitter, Instagram, Snapchat, etc.). 

This list is illustrative only, and not exhaustive. No form of harassment will be tolerated.

Training 

All MPower Persons are required to attend training on this policy.

Complaint Procedure 

If an MPOWER Person is subjected to any conduct that she or he believes violates this policy or witnesses any  such conduct, she or he must promptly speak to, write, or otherwise contact the Compliance Manager or, if the  conduct involves the Compliance Manager, the Directors, ideally within 10 days after the offending conduct.  

The complaint should be as detailed as possible, including the names of all individuals involved and any witnesses.  MPOWER will directly and thoroughly investigate the facts and circumstances of all claims of perceived  harassment and will take prompt corrective action, if appropriate. 

Violations of This Policy 

Any MPOWER Person, regardless of position or title, whom the Compliance Manager or the Directors determine has subjected an individual to harassment or retaliation in violation of this policy, will be subject to  discipline.