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Neil Daniele

Chief Compliance Officer and Secretary at JAPAN SMALLER CAPITALIZATION FUND
Executive

About Neil Daniele

Neil Daniele is the Fund’s Secretary (since 2002) and Chief Compliance Officer (since 2005), age 65 as of October 14, 2025, and a Managing Director at Nomura Asset Management U.S.A. Inc. (“NAM‑U.S.A.”) since 2007; he also serves as Chief Compliance Officer at Nomura Corporate Research and Asset Management Inc. (“NCRAM”) and has served as Corporate Secretary of NAM‑U.S.A. since 2013 . In closed‑end fund filings, officer compensation is not tied to Fund TSR or financial performance; instead, the management agreement requires NAM‑U.S.A. (the manager) to pay all officer compensation, and the Fund discloses only Independent Director fees . As a result, pay‑for‑performance metrics for Daniele (e.g., revenue/EBITDA/TSR linkages) are not disclosed by the Fund; his responsibilities center on compliance oversight, governance, and risk controls across the Fund and NAM‑U.S.A. affiliates .

Past Roles

OrganizationRoleYearsStrategic Impact
NAM‑U.S.A.Managing Director; Chief Compliance OfficerMD since 2007; CCO since 2005Leads compliance program for NAM‑U.S.A. and the Fund; provides governance reporting to the Board and committees .
Japan Smaller Capitalization Fund, Inc. (JOF)Secretary; Chief Compliance OfficerSecretary since 2002; CCO since 2005Officer charged with Fund compliance reporting, Section 16 oversight, and governance processes; signs official correspondence (e.g., fidelity bond filings) .
NCRAM (Nomura Corporate Research & Asset Management Inc.)Chief Compliance OfficerSince 2009Oversees compliance at credit-focused affiliate; provides cross‑entity compliance leadership .
Nomura Funds Research & Technologies America, Inc.Chief Compliance OfficerSince 2009 (historical)Broader Nomura affiliate compliance coverage (historical disclosure) .

External Roles

OrganizationRoleYearsNotes
NAM‑U.S.A.Corporate SecretarySince 2013Corporate governance role at manager; supports Fund governance .
NCRAMChief Compliance OfficerSince 2009External affiliate role; complements Fund CCO responsibilities .
Nomura Funds Research & Technologies America, Inc.Chief Compliance OfficerSince 2009 (historical)Historical external CCO role across Nomura affiliates .

Fixed Compensation

ItemDisclosureSource
Compensation payerNAM‑U.S.A. pays all compensation of Fund officers (and affiliated Directors) under the Management Agreement
Fund‑level officer payNot disclosed; Fund only discloses Independent Director fees
Independent Director fees (context)Annual fee $30,000; $3,300 per in‑person/virtual meeting; $2,200 per telephonic meeting; Chair fees: Board $10k, Audit $5k, Nominating $2.5k, Governance $2.5k
Example Director compensation (FY 2025)Buck $56,500; Chemidlin $54,800; MacHarg $52,300; Ouimet $51,200; Laby $6,600; Andoh $0

Performance Compensation

Incentive ElementDisclosureVesting/TriggersSource
Cash bonus, target %Not disclosed for Fund officers (paid by NAM‑U.S.A.)Not disclosed
Stock awards (RSUs/PSUs)No Fund equity awards disclosed for officersNot disclosed
OptionsNo Fund option grants to officers disclosedNot disclosed
Performance metrics (e.g., TSR/EBITDA)Not linked to Fund‑level officer pay; Fund does not disclose officer performance plan metricsNot disclosed

Equity Ownership & Alignment

ItemDisclosureSource
Officer‑specific JOF holdingsNot itemized; Fund reports group ownership only
Officers & Directors (group)Aggregate ownership less than 1% of outstanding JOF shares (as of Sep 26, 2025)
Pledging/HedgingNo pledging/hedging disclosures for officers in Fund proxy
Ownership guidelinesNot disclosed for Fund officers

Employment Terms

TermDisclosureSource
Election & termOfficers are annually elected/appointed by Directors; serve until resignation/removal/disqualification
CCO oversightGovernance & Compliance Committee oversees compliance policies and recommends CCO designation (Rule 38a‑1)
Contract, severance, change‑of‑controlNo officer employment contracts, severance multiples, or CoC terms disclosed by the Fund; compensation governed by manager agreement
Clawbacks, gross‑ups, perquisitesNot disclosed by the Fund for officers
Section 16 filingsFund states officers/directors/10% holders complied with Section 16(a) reporting in the most recent fiscal year

Additional Governance/Compliance Signals

  • Power of Attorney designations include Daniele as attorney‑in‑fact authorized to sign Forms 3/4/5 for certain insiders, evidencing entrusted compliance authority (March 25, 2014) .
  • Fidelity bond filings and board approvals are addressed under Daniele’s signature as Secretary & CCO, reflecting direct responsibility for risk coverage and controls .

Investment Implications

  • Pay‑for‑performance transparency is low at the Fund level for officers because all officer compensation is paid by NAM‑U.S.A.; Fund proxies do not disclose Daniele’s salary/bonus/equity, nor performance metrics or vesting schedules, limiting direct alignment assessment from Fund documents .
  • Retention risk appears low given very long tenure (Secretary since 2002; CCO since 2005) and continued designation as CCO across Nomura affiliates; any change in NAM‑U.S.A. management structure would be more informative than Fund proxies for retention analysis .
  • Insider selling pressure/trading signals are constrained by minimal officer group ownership (<1% collectively) and lack of itemized officer holdings; monitor Section 16 forms and any future Form 4 filings for signal changes, but Fund confirms compliance in recent periods .
  • Governance confidence: recurring disclosure of committee oversight and compliance program reporting, plus fidelity bond administration under Daniele’s signature, supports robust compliance infrastructure rather than incentive‑driven pay levers at the Fund .