Hirogin Holdings Inc

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Limited	Hirogin Holdings provides only limited visibility into its climate-related lobbying. It indicates that it works on broad themes such as carbon neutrality and sustainable finance and cites involvement in initiatives like the Ministry of the Environment’s ESG finance promotion and TCFD engagement programs, but it does not name any specific bills, regulations, or rule-makings it has tried to influence. The group explains that it partners with local governments, utilities and other companies and takes part in public programmes, showing that it uses collaborative mechanisms, yet it does not identify which government departments, legislators or regulatory agencies are the direct targets of these efforts. Likewise, the company states high-level objectives—achieving carbon neutrality by 2050, reducing greenhouse-gas emissions and supporting renewable energy projects—without detailing the concrete policy changes or quantified outcomes it seeks through its advocacy. As a result, disclosures touch on each of the key areas but remain general and lack the specificity needed for strong transparency.	1

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Hirogin Holdings Inc. has instituted a group-wide framework whereby "当社グループの気候変動対応に関する主要施策は、グループサステナビリティ推進委員会の審議を経て、グループ経営計画等の策定プロセスの中で、取締役会決議により、決定されている", such that its Board of Directors formally approves climate-related measures through a sustainability committee and these directives are cascaded into plans for each subsidiary and department to ensure consistency. In addition, it reports that "全国地方銀行協会の各種方針・施策等について、当該協会との主たる対応部署である広島銀行の東京事務所が、適宜適切に経営陣に対する報告を実施しており、当該協会の施策的方向性を踏まえた広島銀行の取組みの検討・反映の仕組みも講じられている", reflecting oversight of its indirect engagement with industry associations. We found no evidence of a defined process for reviewing or managing direct lobbying activities or a named individual responsible for lobbying oversight. The governance process is clearly structured around Board sign-off and committee deliberations for group strategy, but it does not disclose mechanisms for direct lobbying alignment, indicating moderate governance focused primarily on group planning and indirect association engagement.	2