On September 28, 2010, ACGA wrote a letter to Japan's Ministry of Justice (MOJ) expressing our views on some amendments, including the general model of governance for corporations, the role and authority of statutory auditors (kansayaku), the proper role of directors, and the governance of dilutive capital issues, to the Company Law that the Legislative Advisory Council's Company Law Sub-Committee was considering.

We provided specific comments and suggestions on:

• Independent directors;
• Board committees;
• Role of boards;
• Voting by Kansayaku;
• Shareholder approval rights; and
• The "Joint Audit Committee Company" proposal.