Tokyo Steel Manufacturing Co Ltd

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Limited Tokyo Steel offers a partial window into its climate-policy lobbying. It discloses one identifiable policy focus—the Japanese “Energy Conservation Act,” noting its interest in climate-related reporting requirements—showing some specificity but not a wider map of the policies on which it works. The company explains the channels it used to advance its views, describing “explanation sessions” and “factory tours” arranged for officials from the Ministry of Economy, Trade and Industry and the Agency for Natural Resources and Energy, thereby naming both the mechanisms and the governmental targets of its outreach. On objectives, it sets out a single concrete goal: securing an amendment to the Energy Conservation Act so that electricity drawn through demand-response operations powered by renewables is recognised as renewable consumption, a change it reports was adopted in the April 2023 revision. Beyond that, the narrative remains largely aspirational, referring only in broad terms to encouraging governments to classify electric-arc-furnace steel as low-carbon, recycled steel. Overall, the disclosure provides limited but tangible insight into one policy engagement and two lobbying methods, while leaving the breadth of its lobbying portfolio and the full range of desired policy outcomes unclear. 1
Lobbying Governance
Overall Assessment Comment Score
Limited Tokyo Steel Manufacturing Co Ltd has a “public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement,” reflecting an intention to align its policy engagement with global climate targets. However, the company does not disclose any governance mechanisms such as a named individual or formal body overseeing its lobbying, nor does it describe any monitoring, review or audit process for direct or indirect lobbying activities. We found no evidence of procedures for managing trade-association advocacy, board-level sign-off, or periodic reporting on climate lobbying alignment. 1