KDDI Corp

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Strong	KDDI provides a strong level of transparency around its climate-policy lobbying. It names two concrete policy engagements—the Japanese “Act on the Rational Use of Energy (Energy Conservation Law)” and the Ministry of Economy, Trade and Industry’s “GX League” initiative—giving readers a clear view of the legislative and regulatory instruments it seeks to influence. The company also describes in detail how it lobbies and whom it approaches: it “submitted a request as KDDI” in a public comment process directed at the Agency for Natural Resources and Energy, “announced its support for the GX League concept” through direct collaboration with the Ministry, and “together with other companies affiliated with Keidanren, submitted to the Ministry of Economy, Trade and Industry an improvement proposal for the Act on the rational use of energy.” By identifying both the mechanisms (public comments, formal proposals, participation in policy platforms) and the precise government bodies targeted, the disclosure makes the company’s methods and counterparties clear. Finally, KDDI explains the specific outcomes it seeks: it advocated for “the introduction of emissions intensity regulations, in which the figures after the conversion to emissions resulting from the introduction of renewable energy are treated as numerators,” and states its aim to advance the GX League’s goals of carbon-neutrality by 2050 and a 46 % emissions reduction by 2030. This combination of named policies, explicit lobbying channels, identified targets, and articulated policy goals demonstrates a high degree of openness about the company’s climate lobbying activities.	3

Lobbying Governance

Overall Assessment	Comment	Score
Strong	KDDI has a structured governance process that integrates its direct and indirect policy advocacy with its carbon neutrality strategy, though it does not disclose a dedicated audit or third-party review of its climate lobbying alignment. KDDI’s Policy Coordination Department “constantly collects information on the approaches from policy makers such as the Ministry of Internal Affairs and Communications and the Ministry of Economy, Trade and Industry,” which is then “disseminated to the relevant departments” for review of “key climate change-related tasks” before those departments “report their results to the Carbon Neutrality Subcommittee and the Sustainability Committee.” For indirect engagement, the company explains that “after reporting to the Carbon Neutrality Subcommittee and the Sustainability Committee, we will approach policy makers through Keidanren (Japan Business Federation),” illustrating clear oversight of trade association lobbying. Board-level involvement is evident as the “KDDI Green Partners Fund” was “approved and established by the Board of Directors,” with each investment decision first “reported to the Corporate Management Committee,” linking financial support to start-ups directly to governance bodies. While these elements demonstrate strong processes for managing both direct and indirect lobbying, We found no evidence of a standalone climate-lobbying alignment report or an external assessment of these activities.	3