Japan Exchange Group Inc

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Japan Exchange Group provides a detailed and specific picture of its climate-policy engagement. It names multiple identifiable policies it works on, including the Ministry of Economy, Trade and Industry’s GX League Basic Concept and related “Basic Policy for the Realization of GX” emissions-trading scheme, as well as the Financial Services Agency’s policy on the role of the financial industry in achieving carbon neutrality by 2050, all of which are clearly tied to Japan’s carbon-pricing and disclosure framework. The company is equally explicit about how it engages: it sits on the Financial Services Agency’s Expert Panel on Sustainable Finance, takes part in the Financial System Council Working Group on Disclosure and Assurance, participates in a METI-commissioned Technical Demonstration Project for a Carbon Credit Market, and maintains “close communication with METI” while endorsing the GX League—identifying concrete mechanisms (panel membership, government-run pilot trading, formal endorsements) and specific governmental targets (FSA, METI, Ministry of Finance and Ministry of the Environment). Finally, it sets out the outcomes it is pursuing: establishment of a permanent national carbon-credit market, implementation of an emissions-trading scheme, enhanced corporate climate disclosure and ESG evaluation, and wider capital-market support for Japan’s 2050 carbon-neutrality goal. The combination of clearly named policies, well-described engagement channels and unambiguous policy objectives demonstrates a comprehensive level of transparency around the company’s climate-related lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Japan Exchange Group Inc has established a governance process for climate-related engagement that indicates structured oversight of its direct policy engagement. It states that “engagement related to climate change is done, as a rule, directly by the Sustainability Department, which is in charge of ESG-related activities across the group,” with detailed activities “reported to the Sustainability Committee,” comprised of the CEO (Committee Chair), the COO (Committee Vice-Chair) and the executive officer responsible for sustainability, who “discuss specific activities in response to these reports and ensure that they are aligned with JPX Group's strategy.” This demonstrates a clear mechanism and named oversight for aligning direct climate lobbying with the company’s strategy. However, the company acknowledges “No, and we do not plan to have one in the next two years” when asked about a public commitment to the Paris Agreement, and we found no evidence of any process to manage or align indirect lobbying through trade or industry associations. The company does not disclose broader climate-lobbying alignment policies or reviews beyond direct engagement, indicating that its governance framework does not yet fully address all channels of policy influence or broader climate governance commitments.	2