Japan Airlines Co Ltd – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Strong	Japan Airlines outlines a structured process to oversee and align its policy engagement with its climate strategy, indicating strong governance. The company states that "engagement activities are reported to the Sustainability Promotion Council, chaired by the President, to ensure alignment with the JAL Group's climate change-related strategies," identifying a clear senior-level body with oversight. It further discloses that "all political engagement activities made by JAL Group are monitored and managed by the head office (Corporate Strategy Department・ESG Promotion Department)," providing transparency on the internal departments responsible for day-to-day management. Importantly, the airline addresses both direct and indirect lobbying: it is "actively exchanging opinions and cooperating with policy and industry organizations" and has a detailed five-step protocol for instances "where industry associations have unclear or misalignment positions," including making the misalignment explicit, agreeing on recommendations, and "review progress on agreed actions." This demonstrates an explicit mechanism to review and, where necessary, correct the positions of trade associations. The company also confirms that its engagements are conducted "in line with the goals of the Paris Agreement," signalling a formal policy commitment. However, the disclosure does not mention a publicly available standalone lobbying-alignment report or an external audit of its lobbying activities, and the frequency or outcomes of the misalignment reviews are not described. Overall, the presence of a named oversight body, a management process that covers both direct and indirect lobbying, and a Paris-aligned commitment indicate strong but not comprehensive governance. View Sources	B

Overall Assessment

Analysis

Score

Strong

Japan Airlines outlines a structured process to oversee and align its policy engagement with its climate strategy, indicating strong governance. The company states that "engagement activities are reported to the Sustainability Promotion Council, chaired by the President, to ensure alignment with the JAL Group's climate change-related strategies," identifying a clear senior-level body with oversight. It further discloses that "all political engagement activities made by JAL Group are monitored and managed by the head office (Corporate Strategy Department・ESG Promotion Department)," providing transparency on the internal departments responsible for day-to-day management. Importantly, the airline addresses both direct and indirect lobbying: it is "actively exchanging opinions and cooperating with policy and industry organizations" and has a detailed five-step protocol for instances "where industry associations have unclear or misalignment positions," including making the misalignment explicit, agreeing on recommendations, and "review progress on agreed actions." This demonstrates an explicit mechanism to review and, where necessary, correct the positions of trade associations. The company also confirms that its engagements are conducted "in line with the goals of the Paris Agreement," signalling a formal policy commitment. However, the disclosure does not mention a publicly available standalone lobbying-alignment report or an external audit of its lobbying activities, and the frequency or outcomes of the misalignment reviews are not described. Overall, the presence of a named oversight body, a management process that covers both direct and indirect lobbying, and a Paris-aligned commitment indicate strong but not comprehensive governance.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Japan Airlines discloses a very high level of detail about its climate-policy lobbying. It identifies numerous concrete policies and frameworks it has engaged on, including the Ministry of Land, Infrastructure, Transport and Tourism’s CARATS air-traffic modernisation initiative, the Ministry of Economy, Trade and Industry’s “GX League Basic Concept,” government consultations on the Basic Policy for Aviation Decarbonisation under the amended Civil Aeronautics Act, the public-private council to accelerate Sustainable Aviation Fuel (SAF) deployment, ICAO negotiations on the design and revision of CORSIA, and the adoption of ICAO’s 2050 net-zero target. The airline also explains how it seeks to influence these measures: it sits on government study committees, serves on the SAF promotion council, participates in ICAO working and steering groups, advises Japanese ministries, and makes proposals through the Scheduled Airlines Association of Japan—clearly naming the Japanese MLIT, METI, JCAB and ICAO as its lobbying targets. Finally, JAL spells out the outcomes it is pursuing, such as securing government CAPEX support and tax credits to build a domestic SAF supply chain, achieving 10 % SAF use by 2030, supporting the removal of speed limits in control areas to cut fuel burn, improving air-traffic management through new technologies, and helping shape CORSIA rules to reach sector-wide net-zero CO₂ by 2050. This breadth of policy naming, mechanism description and explicit, measurable objectives demonstrates comprehensive transparency in the company’s climate-related lobbying.	A