On October 29, Hibiki Path Advisors (“we”) filed an Amendment Report (Japanese Only) on Large Shareholding, disclosing that our stake in Tamai Steamship Co., Ltd. (the “Company” or “Tamai Steamship”) increased by over 1%.
Now, our shareholding has reached 7.49% (7.50%¹ excluding treasury shares）.
Prior to the filing of the Amendment Report on Large Shareholdings, our CIO, Yuya Shimizu, met with the Company’s President Kiyozaki, Director Matsumoto and Director Nagai on October 20. During this meeting, we explained our views on the Company’s takeover response policy, as well as the contents of the letter (including the Letter of Request) that we sent to the Company’s Board of Directors on September 25. When we inquired about the status of the Company’s response policy, President Kiyozaki stated that “there is a possibility that Mr. Sun and ISC are acting in concert, and that we are still in the process of verifying this. Since we have not yet obtained a response suitable for disclosure to investors, the discussions are continuing.”
Tamai Steamship disclosed on September 1, in its “Notice of Receipt of Response to Letter of Inquiry to Mr. Sun You Ning and ISC (Japanese Only)” that it had received answers to its Letter of Inquiry addressed to ISC on August 22, 2025 and to Mr. Sun dated August 31. However, although more than two months have elapsed since the receipt of responses from Mr. Sun and ISC, and two weeks have passed since our meeting in which we requested prompt disclosure, Tamai Steamship has neither reported the result of its deliberation of its large-scale purchase response policy nor provided an interim update.
We have repeatedly urged the Company to promptly disclose information that aids the general shareholders’ understanding of the current situation. We are disappointed by the Company’s management, which appears to disregard these sincere requests. In light of this response, we intend to thoroughly assess whether the current management possesses the necessary qualifications and capabilities, and will determine our voting decisions at next year’s shareholders’ meeting accordingly.
As noted in our previous letter, we are deeply concerned that the management team, instead of taking clear and effective steps to enhance corporate value, has allowed the stock price to remain persistently low and issued a large-scale purchase response policy that essentially “endorses the current management and existing governance structure.” While views may differ depending on one’s standpoint, from our perspective, the introduction of this policy appears to be motivated by “the incumbent management’s self-preservation”, and we struggle to interpret it otherwise.
As we noted in our public letter to our portfolio companies titled “Merits and Challenges of Being Publicly Listed”, disclosed on October 24, 2024, we regard the most important significance of being publicly listed as a “powerful tool to win in a competitive landscape”. Specifically, it allows companies to secure a fair stock valuation in the market and competitive advantages that then enable dynamic growth strategies in M&A and capital raising by gaining market support. We once again urge the Company to swiftly and earnestly consider what structure would best serve the interests of all stakeholders, including those within your Company.
We remain committed to exploring every possible path toward maximizing Tamai Steamship’s corporate value. To our fellow shareholders and to all employees, who are the true source of the Company’s value, we sincerely call on you to continue supporting.
¹ FY 3/26 Q1 Summary of Financial Results (Japanese only) End of Quarter’s Number of Treasury Shares (1,849) used
（Past Posts）
29/Sep/2025 – Large Shareholding Report and Letter to Tamai Steamship
This document does not solicit applications for or recommend the sale of certain securities, or provide advice on investment, legal, tax, accounting, etc. In respect of information that has been prepared by Hibiki Path Advisors (and not otherwise attributed to any other party) and which appear in the English language version of this letter, in the event of any inconsistency between the English language version and the Japanese language version of this document, the meaning of the Japanese language version shall prevail unless otherwise expressly indicated engagement amongst all shareholders.