Toho Gas Co Ltd

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Limited	Toho Gas provides only limited transparency on its climate-related lobbying. It identifies one specific policy it has engaged on—the Ministry of the Environment’s “Decarbonization Leading Areas” initiative—and explains the policy’s objective of achieving net-zero residential electricity emissions by 2030. Beyond this, references to the U.S.-Japan Memorandum of Cooperation on CCUS are described only as general alignment rather than active lobbying, so the breadth of policy disclosure remains narrow. The company does describe two concrete lobbying mechanisms and their targets: it worked with Nagoya City to submit a formal proposal to the Ministry of the Environment and presented its plan to the Decarbonization Leading Areas Evaluation Committee, demonstrating direct engagement with identifiable government bodies. Regarding desired outcomes, Toho Gas states that it wants approval for a decarbonised compact-city model in the Minato Aquls smart town that would deliver net-zero CO₂ from electricity use by 2030 and details technical measures it would deploy, but it does not articulate additional or broader legislative changes it is seeking. Overall, the disclosures reveal some information about the company’s lobbying channels and immediate objectives, but they do not cover multiple policies or provide a fuller picture of the outcomes it advocates, resulting in a limited level of transparency.	1

Lobbying Governance

Overall Assessment	Comment	Score
Limited	Toho Gas Co Ltd discloses general climate governance structures but provides no specific processes for governing its lobbying activities. While it highlights that “the Carbon Neutral Promotion Committee comprises executive officers… including the Toho Gas Company President and Representative Director” and that “the Group Sustainability Committee comprising directors and department heads… discusses and checks policies and targets toward sustainability,” we found no evidence of any mechanism to manage, monitor, or align its lobbying, direct or indirect, with its climate policies. The only relevant statement is its affirmative response—“Yes”—to having “a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement,” but the company does not disclose how such engagement is defined, who oversees it, or what processes ensure its advocacy remains consistent with its climate objectives.	1