The evidence is clear: codes change behavior. Japan's GPIF saw climate engagement cases increase 3.4 times in the four years following its code revision, and collective engagement by Australian ACSI signatories drove TCFD adoption among ASX200 companies from 10% to 82% over seven years. The NPS, by contrast, is moving in the opposite direction. The number of companies subject to climate risk management engagement fell from 29 in 2024 to 13 in Q3 2025, and average engagement per company stood at just 1.1 times in 2024. There are no climate-related criteria in its voting guidelines. While the NPS references ESG in its own stewardship principles, the fundamental problem is that the Korean stewardship code on which those principles rest contains no climate provisions, leaving the basis for meaningful implementation critically weak.

This report proposes five principles for revising Korea's stewardship code to incorporate climate factors:

1. Redefine stewardship — explicitly recognize climate and ESG as core elements of fiduciary responsibility

2. Establish climate and ESG investment principles — make climate factors mandatory from the policy-setting stage

3. Provide a basis for climate engagement and monitoring — establish climate risk as an official item for review and engagement

4. Introduce climate-related voting criteria — create an actionable link between climate stewardship commitments and voting practice

5. Build a climate stewardship disclosure framework — establish an accountability structure subject to external verification

The code must change for practice to change.