POSCO Future M Co Ltd

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Limited	POSCO Future M is relatively clear about which climate policies it interacts with, naming the Republic of Korea’s “Act on Allocation and Trading of Greenhouse Gas Emission Permits,” the supporting “Guidelines for Reporting and Certification of Emissions under the Greenhouse Gas Emissions Trading Scheme,” and the Ministry of Environment’s “Notice No. 2022-279,” and explaining that the company has been a designated entity under the national emissions-trading system since 2015. Beyond listing these measures, however, the company offers little insight into how it seeks to influence them: the disclosure only states in general terms that it is “engaging with various GHG reduction business” and that it participates in the trading system by “selling and buying an excess or shortage of the right,” without specifying whether it meets officials, submits consultation responses, or works through industry associations, nor does it identify any particular governmental targets for those activities. Likewise, the company’s policy stance is expressed only at a high level— it “support[s] with no exceptions” Korea’s ETS and aligns itself with achieving national net-zero goals—without describing any concrete amendments, thresholds, or timetable it is advocating. As a result, while the policies being addressed are clearly named, transparency about the company’s lobbying mechanisms and the precise outcomes it seeks remains limited.	1

Lobbying Governance

Overall Assessment	Comment	Score
None	POSCO Future M Co Ltd’s disclosures describe its corporate citizen management structure centered on a "기업시민사무국" and an "ESG관리 TF" that addresses ESG issues such as "이슈 발굴 및 가이드" and "전사 임직원 대상 ESG 교육", but we found no evidence of any policy, process, or oversight for managing lobbying activities, either direct or indirect, in relation to climate or other policy goals. There is no mention of board oversight or a responsible individual for lobbying alignment, nor any description of monitoring or management procedures for policy engagement. The company also states "Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement? […] No, but we plan to have one in the next two years," which indicates it has not yet established such a commitment. This lack of disclosure indicates no governance framework for lobbying alignment is publicly available.	0