SG Holdings Co Ltd

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Strong	SG Holdings discloses a solid level of detail about its climate-policy lobbying. It names two specific Japanese climate laws that it engages on—the “エネルギーの使用の合理化等に関する法律” and the “地球温暖化対策の推進に関する法律”—and describes work on the forthcoming revision of the Energy Conservation Act (“省エネ改正法”). The company is especially clear about how it lobbies: it takes part in forums that “定期的に経済産業省・環境省の産業技術環境局長、地球環境局長を招き”, holds “ヒアリングと意見交換” with those ministries, and conducts separate “対話” sessions with the Ministry of Land, Infrastructure, Transport and Tourism. By identifying the ministries and even the senior officials involved, and by describing mechanisms such as hearings, formal exchanges of views and multi-stakeholder round-tables, the company provides transparency on both method and target. It also spells out what it wants to achieve, for example “EV導入助成金について意見交換” to shape subsidy requirements and discussions on “物流車両の脱炭素化への現状、課題、行政に期待すること” to accelerate decarbonisation measures for logistics vehicles. While the disclosures do not cover a wide array of separate policies or list more than two concrete legislative outcomes, they give clear insight into the company’s priorities and the channels it uses, demonstrating a strong overall level of transparency.	3

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	SG Holdings Co Ltd discloses a structured governance framework for its policy engagement, noting that “各事業会社内での上程・報告・承認・指示プロセスのもと実施されています,” and assigning its President and COO as “responsible for supervising the Group’s policies and responses related to climate change issues.” It also explains that “issues related to climate change are reported and discussed at the Sustainability Committee with the representative director and directors as members, and reported to the Board of Directors as needed,” and affirms “Yes” when asked if it has a public commitment to align its engagement activities with the goals of the Paris Agreement. While this demonstrates clear oversight, defined procedures, and explicit leadership for direct lobbying governance, the company does not disclose any mechanism for reviewing or managing its indirect lobbying through participation in bodies such as the Japan Climate Leaders Partnership or other trade association committees to ensure those channels also reflect its climate commitments.	2