On November 25, 2014, ACGA wrote to the Financial Services Agency (FSA) of Japan with a series of preliminary recommendations for the country's forthcoming Corporate Governance Code. Our comments covered issues such as the operation of the "comply or explain" principle, the need for some degree of practical guidance to issuers on governance best practices (ie, the Code should not just be a set of principles), and the need for the Code to address local issues in Japan, among other things.