Nexen Tire Corp

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Moderate	Nexen Tire Corp demonstrates a moderate level of transparency in its climate-policy lobbying disclosures. It clearly names the Emission Trading System of Korea—detailing its inception in 2015, the current 2021–25 phase, and the 90% free allocation of allowances—thereby providing an identifiable focus for its policy engagement. The company outlines its lobbying mechanisms, citing methods such as “directly suggest[ing] to government agencies whenever related laws and guidelines are revised” and “participat[ing] in public hearings and briefing sessions on climate-related issues,” although it refers generically to “government agencies” without specifying particular bodies. Its stated policy objectives include supporting mandatory climate-related reporting and proposing an alternative GHG emission allocation mechanism—“a multi-emission company can be restrained according to the characteristics of the company”—and it affirms its alignment with the Paris Agreement. This combination of specificity around a key policy, clear description of engagement methods, and articulation of distinct outcomes sought reflects a moderately comprehensive disclosure of its climate lobbying activities.	2

Lobbying Governance

Overall Assessment	Comment	Score
None	Nexen Tire Corp has established internal structures such as “we will organize ESG response Operating Committee and the ESG Committee to manage our ESG status and issues and approve mid- to long-term ESG plans through linkage to the management’s environmental change response and corporate strategies,” and “responds to key ESG-related issues through the Strategy Planning Team of the Business Administration Business Group under the CEO,” yet the company does not disclose any governance processes or oversight specifically for lobbying, nor any mechanisms to align direct or indirect lobbying with its climate objectives. We found no evidence of any lobbying policy, dedicated review or monitoring procedure, or named individual or committee charged with overseeing lobbying activities.	0