China Steel Corp – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Comprehensive	China Steel Corp (CSC) demonstrates a comprehensive governance process for climate lobbying, with clear mechanisms for ensuring alignment with its climate-related goals and commitments. CSC has established a Corporate Governance and Sustainability Committee, which is tasked with overseeing sustainability-related matters, including energy conservation, carbon reduction, and carbon neutrality. This committee reports regularly to the Board of Directors, ensuring accountability and transparency. CSC explicitly states that its engagement activities are consistent with its climate strategy, noting that "regular meetings (once every 2-3 months) are held by the CSC Energy Conservation and the Carbon Reduction & Neutral Promotion Unit to check whether the engagement works or not." Furthermore, CSC has implemented a robust process for managing indirect lobbying through trade associations, including a policy to "request the organization to adjust its climate change stance within six months of our reiteration to align with international or domestic sustainable development goals. If the organization fails to do so within the specified period, the Company will terminate our cooperation with the organization." This indicates active alignment of indirect lobbying with climate goals. CSC also conducts a "Survey of Climate Policy Preferences" every two years to assess the alignment of organizations it participates in with climate goals, demonstrating a structured monitoring mechanism. Additionally, the company has disclosed that the chairman of the board heads the task force on energy saving, carbon reduction, and carbon neutrality, further emphasizing high-level oversight. CSCs commitment to aligning its lobbying activities with the Paris Agreement and its net-zero target by 2050 is evident, as it actively collaborates with organizations taking climate action and ensures that "all our indirect climate advocacy actions remain consistent with the Paris Agreement." The publication of detailed guidelines and surveys further reinforces the transparency and depth of its governance framework. View Sources	A

Overall Assessment

Analysis

Score

Comprehensive

China Steel Corp (CSC) demonstrates a comprehensive governance process for climate lobbying, with clear mechanisms for ensuring alignment with its climate-related goals and commitments. CSC has established a Corporate Governance and Sustainability Committee, which is tasked with overseeing sustainability-related matters, including energy conservation, carbon reduction, and carbon neutrality. This committee reports regularly to the Board of Directors, ensuring accountability and transparency. CSC explicitly states that its engagement activities are consistent with its climate strategy, noting that "regular meetings (once every 2-3 months) are held by the CSC Energy Conservation and the Carbon Reduction & Neutral Promotion Unit to check whether the engagement works or not." Furthermore, CSC has implemented a robust process for managing indirect lobbying through trade associations, including a policy to "request the organization to adjust its climate change stance within six months of our reiteration to align with international or domestic sustainable development goals. If the organization fails to do so within the specified period, the Company will terminate our cooperation with the organization." This indicates active alignment of indirect lobbying with climate goals. CSC also conducts a "Survey of Climate Policy Preferences" every two years to assess the alignment of organizations it participates in with climate goals, demonstrating a structured monitoring mechanism. Additionally, the company has disclosed that the chairman of the board heads the task force on energy saving, carbon reduction, and carbon neutrality, further emphasizing high-level oversight. CSCs commitment to aligning its lobbying activities with the Paris Agreement and its net-zero target by 2050 is evident, as it actively collaborates with organizations taking climate action and ensures that "all our indirect climate advocacy actions remain consistent with the Paris Agreement." The publication of detailed guidelines and surveys further reinforces the transparency and depth of its governance framework.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	China Steel Corporation discloses extensive detail on every aspect of its climate-policy lobbying. It explicitly names the measures it engages on, including the "Renewable Energy Development Act: Regulations for the Management of Setting up Renewable Energy Power Generation Equipment of Power Users above a Certain Contract Capacity," the "Climate Change Response Act" (and the associated carbon-fee and emissions-trading provisions), and the EPA’s forthcoming carbon-levy scheme, as well as related sub-laws announced on 31 December 2020. The company also spells out its methods and the policymaking bodies it targets. It reports that it "repeatedly expressed opinions to the Bureau of Energy in several communication meetings of the draft sub-law," "actively communicated with the Environmental Protection Agency regarding this matter," "has consistently discussed with the members of the Legislative Yuan," and "talks with policy makers directly to look for support from the legislative side," while also working through trade associations such as the Chinese National Federation of Industries and the Taiwan Steel & Iron Industries Association. Finally, CSC is clear about the outcomes it seeks. It has urged that "the government should recognize the installed capacity of renewable energy" rather than obliging companies to self-consume that power, asked that "metallurgical coal and coke for the steel industry" be exempted from any carbon levy to protect competitiveness, recommended that "the central government…integrate the differences between stricter local regulations and central regulations," and advocated that “some important principles like the maximum of carbon fee, and no double control…need to be insert into the Act.” These specific, measurable requests show precisely how the company wants legislation amended. Taken together, these disclosures demonstrate a comprehensive level of transparency about CSC’s climate-related lobbying activities.	A