MS&AD Insurance Group Holdings Inc

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	MS&AD Insurance Group Holdings Inc has demonstrated a comprehensive level of transparency regarding its climate lobbying activities. The company has clearly named specific climate policies it has engaged with, including Japan's emissions trading scheme under the GX League, the Earth Observation Promotion Strategy, and the disclosure standards under the Japanese National Standards and the ISSB of the IFRS Foundation. It also disclosed its focus on green infrastructure utilization for national resilience and regional revitalization, as well as decarbonization policies promoted by national and local governments. MS&AD Insurance Group has been transparent about its lobbying mechanisms, detailing its participation in various committees and platforms, such as the Green Infrastructure Public-Private Partnership Platform under the Ministry of Land, Infrastructure, Transport and Tourism, the Ministry of Education, Culture, Sports, Science and Technology's discussions on climate change measures, and the Earth Observation Promotion Subcommittee. The company also disclosed direct engagement mechanisms, such as submitting public comments and communicating opinions on policy drafts. Furthermore, the company has outlined the specific outcomes it seeks, including supporting Japan's emissions trading scheme under the GX League, promoting the utilization of green infrastructure for climate change adaptation, enhancing regional decarbonization efforts, and influencing national science and technology policies to utilize Earth observation data for resilience and adaptation. These disclosures reflect a high degree of clarity and detail in the company's climate lobbying activities and objectives.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	The evidence reveals that the organization has established a process to ensure that its external engagement activities, which include elements of climate-related lobbying, align with its climate commitments. As disclosed, "気候変動に関する活動は、エンゲージメント活動は、サステナビリティ所管部署に報告され、整合性を確認している" and "重要な事項は、CSuO、サステナビリティ委員会に外部環境として報告されている," indicating that significant climate-related activities are monitored by dedicated entities such as the Sustainability Department, the Chief Sustainability Officer, and the Sustainability Committee. Furthermore, additional disclosures note that indirect activities, such as memberships in industry associations driven by initiatives like achieving Net Zero by 2050, are managed by the line of control with oversight by a director and an officer in charge, as shown by phrases like "the status of their membership and activities are managed by the line of control" and "material matters are reported to the officer in charge." Although some evidence focuses more broadly on ESG and climate risk management without explicitly detailing lobbying governance mechanisms, the presence of clearly defined oversight structures and designated responsible parties for verifying alignment with climate goals indicates a strong governance framework for managing both direct and indirect climate lobbying efforts.	3