Hyundai Rotem Co Ltd

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Strong	Hyundai Rotem provides a solid picture of its climate-related advocacy. It explicitly identifies the South Korean “Carbon Neutrality and Green Growth Basic Act,” explaining how the 2030 emissions-reduction target and local carbon-neutrality planning requirements shape its engagement, but this is the only piece of legislation it names. The company gives rich detail on how it seeks to influence policy: it submits project proposals, takes part in formal consultations, meets with the National Assembly and the Ministry of Land, Infrastructure and Transport, and supplies data and presentations to government officials, clearly identifying both the mechanisms and the policymaking targets. It is equally clear about the results it wants from these interactions, aiming to help Ulsan become a hydrogen city through the deployment of hydrogen-electric trams, to create a hydrogen liquefaction value chain with Gangwon Province and Samcheok City, and to build refuelling stations and storage facilities by 2024—all tied to the broader objective of advancing a hydrogen society. Together, this information shows a high degree of transparency on how and why the company lobbies on climate policy, although its disclosure is limited to a single named law.	3

Lobbying Governance

Overall Assessment	Comment	Score
Limited	Hyundai Rotem provides only limited insight into how it governs climate-related lobbying or policy engagement. The company states that it has a "public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement… Yes," and explains that it seeks to align with national climate policies by "reorganizing business portfolio and actively participating national projects" and by withdrawing from coal-related activities in favour of hydrogen infrastructure. However, the disclosure focuses on business strategy rather than a formal governance process: while it describes engagement with government initiatives, it does not identify any specific individual or board committee that oversees lobbying, gives no details of internal monitoring or sign-off procedures, and offers no evidence that it reviews the positions of trade associations or manages indirect lobbying. Consequently, the company demonstrates only a general commitment to align engagement activities with climate goals, but it does not disclose a structured governance mechanism to ensure, review, or enforce that alignment.	1