Hakuhodo DY Holdings Inc

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Limited Hakuhodo DY Holdings provides only limited insight into its climate-policy lobbying. The company acknowledges that it has engaged with Japan’s national climate agenda, stating its focus on “Japan’s CO2 reduction targets and the implementation projects promoted by the Ministry of Environment,” but it does not identify any specific law, regulation or bill beyond this broad reference. The disclosures describe activity such as “promoting specific actions to reduce CO2 emissions” and using digital media to encourage behavioural change, yet they do not explain how these activities constitute lobbying, what concrete channels (e.g., meetings, submissions, letters) were used, or which government officials or bodies were approached. Similarly, the desired outcome is framed only in general terms—“encouraging individual citizens to take action” and helping Japan meet its reduction targets—without spelling out the concrete policy changes or legislative amendments the company seeks. The absence of detailed mechanisms, named targets, or precise policy objectives means the overall transparency of its climate-lobbying disclosure remains low. 1
Lobbying Governance
Overall Assessment Comment Score
Moderate Hakuhodo DY Holdings Inc has established a formal governance mechanism through its Sustainability Committee, which “decides the company’s climate change strategy” and ensures that decision-making “includes alignment with climate change policy trends.” This approach is reinforced by its environmental management system, in which the “cooperation status of departments involved in specific policies” is “regularly confirmed” for consistency with the approved climate-change strategy. However, the company does not disclose any processes specifically governing its direct lobbying activities, nor does it describe how it reviews or manages the positions of trade or industry associations. We found no evidence of a dedicated audit or third-party review of climate lobbying alignment, and no individual beyond the Sustainability Committee is named as responsible for oversight or sign-off on these engagement efforts. 2