Mitsubishi Corp – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Strong	Mitsubishi Corporation has established a governance process to ensure that its policy engagement is aligned with its climate strategy. It requires that “each Group Chief Sustainability Officer is charged with confirming whether these activities are consistent with MC’s climate strategy,” while the “Corporate Sustainability & CSR Dept. is consulted on a case-by-case basis to confirm the content of these activities and their consistency with MC’s climate strategy.” These reviews are reported up to a Corporate Functional Officer “who serves concurrently as a Member of the Board and Executive Vice President,” and ultimately to the Executive Committee and Board of Directors, which “determines the basic policies and other important matters regarding climate change” after deliberation by the Sustainability & CSR Committee and advice from external experts of the Sustainability Advisory Committee. The company explicitly covers both direct engagement through “collaboration, joint initiatives and dialogue with public sector bodies” and indirect lobbying via “business association activities” with bodies such as the Japan Business Federation (Keidanren) and the Japan Chamber of Commerce and Industry. However, Mitsubishi Corporation does not disclose any publicly available audit or detailed report evaluating its climate-related lobbying alignment, nor does it have a commitment to conduct its engagement in line with the goals of the Paris Agreement, stating that it has “no plan to have one in the next two years.” View Sources	B

Overall Assessment

Analysis

Score

Strong

Mitsubishi Corporation has established a governance process to ensure that its policy engagement is aligned with its climate strategy. It requires that “each Group Chief Sustainability Officer is charged with confirming whether these activities are consistent with MC’s climate strategy,” while the “Corporate Sustainability & CSR Dept. is consulted on a case-by-case basis to confirm the content of these activities and their consistency with MC’s climate strategy.” These reviews are reported up to a Corporate Functional Officer “who serves concurrently as a Member of the Board and Executive Vice President,” and ultimately to the Executive Committee and Board of Directors, which “determines the basic policies and other important matters regarding climate change” after deliberation by the Sustainability & CSR Committee and advice from external experts of the Sustainability Advisory Committee. The company explicitly covers both direct engagement through “collaboration, joint initiatives and dialogue with public sector bodies” and indirect lobbying via “business association activities” with bodies such as the Japan Business Federation (Keidanren) and the Japan Chamber of Commerce and Industry. However, Mitsubishi Corporation does not disclose any publicly available audit or detailed report evaluating its climate-related lobbying alignment, nor does it have a commitment to conduct its engagement in line with the goals of the Paris Agreement, stating that it has “no plan to have one in the next two years.”

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Mitsubishi Corporation provides a high level of transparency about its climate-policy lobbying. It names a range of specific measures it has sought to shape, including the Japanese carbon credit system, the forthcoming Japanese climate-related disclosure standard, and domestic implementation of the TCFD framework, as well as legislation to accelerate renewable energy, hydrogen, virtual power plants and other storage-related businesses. The company is equally explicit about how and with whom it engages: it dispatches employees and an executive officer to government committees that make recommendations on the carbon-credit market and disclosure rules, participates in the Resource and Fuel Working Group of the Advisory Committee for Energy Resources at METI, and holds one-on-one meetings and conference discussions with the Ministry of Economy, Trade and Industry (METI), the Financial Services Agency (FSA) and the Ministry of the Environment (MOE). Finally, Mitsubishi spells out the concrete outcomes it seeks—such as establishing “the position of carbon credits and the establishment of a carbon credit market in Japan,” shaping the “structure of annual securities reports” and other elements of the disclosure standard, promoting wider corporate adoption of TCFD guidance, and securing “related legislation to support” the scale-up of hydrogen, VPP and energy-storage businesses. This detailed disclosure of policies, mechanisms and desired outcomes demonstrates comprehensive transparency regarding its climate-lobbying activity.	A