TOKAI Holdings Corp – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	TOKAI Holdings discloses that climate-related external engagement, including the content of those activities, is overseen through its “サステナビリティ推進委員会（議長：CEO）”, explaining that this committee “evaluate[s] and review[s] initiatives” and “審議検討を行ってる” on engagement connected to climate issues, and that it acts as “an advisory body to its Board of Directors.” This indicates a defined process and a clear senior owner for ensuring alignment, and the company adds that it has “a public commitment … to conduct … engagement activities in line with the goals of the Paris Agreement”. However, the disclosure does not specify how the committee assesses or corrects the company’s direct lobbying positions or those of its trade associations, nor does it describe any formal review cycle or criteria for withdrawing from misaligned bodies. Because the company describes a governance mechanism and responsible party but gives limited detail on monitoring methods or coverage of indirect lobbying, this represents a moderate level of transparency rather than a comprehensive approach. View Sources	C

Overall Assessment

Analysis

Score

Moderate

TOKAI Holdings discloses that climate-related external engagement, including the content of those activities, is overseen through its “サステナビリティ推進委員会（議長：CEO）”, explaining that this committee “evaluate[s] and review[s] initiatives” and “審議検討を行ってる” on engagement connected to climate issues, and that it acts as “an advisory body to its Board of Directors.” This indicates a defined process and a clear senior owner for ensuring alignment, and the company adds that it has “a public commitment … to conduct … engagement activities in line with the goals of the Paris Agreement”. However, the disclosure does not specify how the committee assesses or corrects the company’s direct lobbying positions or those of its trade associations, nor does it describe any formal review cycle or criteria for withdrawing from misaligned bodies. Because the company describes a governance mechanism and responsible party but gives limited detail on monitoring methods or coverage of indirect lobbying, this represents a moderate level of transparency rather than a comprehensive approach.

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Lobbying Transparency

Overall Assessment	Analysis	Score
None	No evidence found	E