HD Hyundai Heavy Industries Co Ltd

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Limited	HD Hyundai Heavy Industries provides some, but not extensive, visibility into its climate-related lobbying. It names one specific policy it seeks to influence – the Republic of Korea Emissions Trading System for the third compliance period (2021-2025) – describing the size of the market and its relevance to the company, but it does not list any other climate measures on which it has lobbied. The company explains the method it used by noting that it “engaged directly with the Ministry of Environment in the Republic of Korea” to make its case, yet no other mechanisms (e.g., written submissions, coalition work, or parliamentary testimony) are disclosed. It is nevertheless explicit about the result it wants, advocating that allowance allocations under the ETS “be calculated on the basis of lifecycle greenhouse-gas reductions associated with low-carbon ships,” including a request for credits that offset the short-term rise in emissions from energy-intensive production of those vessels. While this shows clarity on one lobbying objective, the absence of additional policies, limited description of engagement channels, and focus on a single outcome leave important gaps in the overall picture of the company’s climate-policy lobbying.	1

Lobbying Governance

Overall Assessment	Comment	Score
Limited	HD Hyundai Heavy Industries discloses only a limited reference to climate-lobbying alignment, noting "Yes" to having "a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement". The rest of the available information concerns general ESG oversight, such as "seven affiliates of HHI Group established an ESG committee at the Board of Directors level… to deliberate on the planning and implementation of ESG strategies" and "newly formed organizations directly under the CEO oversight for environmental management-related tasks", which focus on environmental management rather than the governance of lobbying or policy advocacy. We found no evidence of a specific process to monitor or review direct or indirect lobbying, no description of how misalignment with trade associations would be addressed, and no individual or committee cited as responsible for ensuring lobbying consistency with climate goals. Hence, the disclosure reflects an initial commitment but lacks details of a structured lobbying-governance framework.	1