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| Overall Assessment |
Comment |
Score |
| Moderate |
NTT Data discloses a fair amount of detail on its climate-policy engagement but stops short of full transparency. It identifies two concrete Japanese initiatives it has lobbied on: the Ministry of Economy, Trade and Industry’s (METI) proposed “Rules on product carbon footprint calculations and verification for supply chain-wide carbon neutrality” and METI’s work on “battery recycling included in the strategy for a growth-oriented, resource-autonomous circular economy.” The company explains how it intervened, noting that it worked indirectly through the Japan Electronics and Information Technology Industries Association, which submitted the document “A Number of Points on CFP Guidelines” to METI’s study group, and that it also engaged directly with METI after being commissioned to consider battery-traceability rules. These disclosures reveal both the mechanism (industry-association submissions and participation in a government-commissioned project) and the policymaking target (METI). On desired outcomes, the firm states that it “Support[s] with no exceptions” the product-carbon-footprint rules and is broadly supportive of the battery-recycling strategy, taking a “position … Support with major exceptions,” but it does not spell out the specific amendments it seeks. Overall, the company provides clear information on the policies addressed and the channels used, while giving only limited detail on the precise legislative or regulatory changes it is advocating.
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2
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| Overall Assessment |
Comment |
Score |
| Limited |
NTT Data discloses a basic oversight structure for ensuring that its climate-related “engagement activities are consistent with your overall climate change strategy,” noting that such actions “are undertaken across the company under the direction of the Climate Change Action Promotion Committee, headed by the Representative Director, Vice President & Executive Officer, with progress being managed by our officers,” and that “The Board of Directors supervises the results of the activities of the Climate Change Action Promotion Committee as a management issue.” This indicates that a named committee and the Board review and sign-off on climate engagement, suggesting some internal controls over advocacy; however, the disclosure does not clarify whether the process covers direct lobbying, indirect lobbying through trade associations, or how alignment is monitored or enforced beyond periodic progress reports, and we found no evidence of a formal lobbying audit, detailed monitoring procedures, or actions taken to address potential misalignment. The company does state it has “a public commitment … to conduct your engagement activities in line with the goals of the Paris Agreement,” yet it does not disclose any mechanism demonstrating how lobbying activities are tested against that commitment. Overall, the governance description is limited and high-level, without the detailed processes, trade-association oversight, or public reporting that would indicate stronger lobbying governance.
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1
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