Tokyo Gas Co Ltd

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Tokyo Gas presents a highly detailed picture of its climate-policy lobbying. It names at least four specific measures it has engaged on—the National Urban Planning System, the Tokyo and Saitama Emissions Trading System, the mandatory carbon-reporting regime (温室効果ガス排出量の算定報告公表制度), and the Tokyo Metropolitan Environmental Basic Plan—clearly identifying the jurisdiction and subject matter of each. The company also explains how it lobbies and whom it targets, describing the use of “対話を行う” (direct dialogue) with “政策担当者”, undertaking joint research with universities, providing expert testimony on GHG calculation methods, and conveying its views as a member of the Tokyo Metropolitan Environmental Council appointed by the Governor—each time specifying the relevant policymakers responsible for the cited policies. It is equally explicit about the results it seeks: integrating energy-efficiency considerations such as gas cogeneration and smart energy networks into urban-planning rules; opposing the Tokyo-area emissions-trading scheme because “排出量取引には反対している” on economic grounds and instead advocating “排出量削減の自主的な行動目標と実績管理のPDCAサイクル”; and pushing for the grid-emission factor used in carbon reporting to be based on marginal gas-fired generation, a change it notes was ultimately incorporated into the Global Warming Countermeasures Promotion Act. This level of specificity across policies, mechanisms, and desired outcomes demonstrates comprehensive transparency in the company’s climate-related lobbying disclosures.	4

Lobbying Governance

Overall Assessment	Comment	Score
Limited	Tokyo Gas Co Ltd states that it has a public commitment to conduct its engagement activities in line with the goals of the Paris Agreement, answering "Yes" to the question "Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?". However, the company does not disclose any details on oversight structures, no mention of a specific individual or committee overseeing lobbying alignment, no processes for monitoring or managing its direct or indirect lobbying, and no indication of audit or review mechanisms for climate lobbying alignment. We found no evidence of engagement with or correction of trade associations whose positions may conflict with its climate policy. This indicates limited transparency and accountability in its lobbying governance.	1