Mizuho Financial Group Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Mizuho Financial Group discloses a governance structure that links its climate-related engagement activities to senior oversight, indicating a moderate level of control over how the group lobbies on climate issues. The company explains that it "established a new Sustainability Promotion Committee within our business execution line to discuss and coordinate sustainability-related matters" and that the committee, which includes the "President & Group CEO, Group Chief Strategy Officer, Group Chief Risk Officer, and Group Chief Financial Officer" as well as outside experts, met twice in FY2021 to review topics such as "Mizuho’s Approach to Achieving Net Zero by 2050 and our climate-related risk management system." It also states that "constructive discussions are held" at Board of Directors and Risk Committee level, where outside directors provide feedback that "it is essential to engage not only with corporate clients but also with governmental agencies and other stakeholders" and that "we must carefully consider the impact of engagement, and effective measures must be taken." In addition, the company answers "Yes" when asked whether it has "a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement," signalling an explicit pledge to align advocacy with climate goals. Taken together, this provides evidence of (i) a stated policy commitment to Paris-aligned engagement and (ii) clearly named committees and senior executives responsible for reviewing and guiding those activities, which indicates a defined—though not yet comprehensive—process for governing climate-related lobbying. However, the disclosure does not detail how direct lobbying positions are monitored in practice, offers no description of how trade-association stances are assessed or corrected, and provides no published audit of alignment; thus, the transparency and scope of the governance remain limited. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Mizuho Financial Group discloses a governance structure that links its climate-related engagement activities to senior oversight, indicating a moderate level of control over how the group lobbies on climate issues. The company explains that it "established a new Sustainability Promotion Committee within our business execution line to discuss and coordinate sustainability-related matters" and that the committee, which includes the "President & Group CEO, Group Chief Strategy Officer, Group Chief Risk Officer, and Group Chief Financial Officer" as well as outside experts, met twice in FY2021 to review topics such as "Mizuho’s Approach to Achieving Net Zero by 2050 and our climate-related risk management system." It also states that "constructive discussions are held" at Board of Directors and Risk Committee level, where outside directors provide feedback that "it is essential to engage not only with corporate clients but also with governmental agencies and other stakeholders" and that "we must carefully consider the impact of engagement, and effective measures must be taken." In addition, the company answers "Yes" when asked whether it has "a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement," signalling an explicit pledge to align advocacy with climate goals. Taken together, this provides evidence of (i) a stated policy commitment to Paris-aligned engagement and (ii) clearly named committees and senior executives responsible for reviewing and guiding those activities, which indicates a defined—though not yet comprehensive—process for governing climate-related lobbying. However, the disclosure does not detail how direct lobbying positions are monitored in practice, offers no description of how trade-association stances are assessed or corrected, and provides no published audit of alignment; thus, the transparency and scope of the governance remain limited.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Mizuho Financial Group offers a comprehensive picture of its climate-policy lobbying. It names multiple concrete initiatives it has helped shape, including the “Basic Guidelines for Climate Transition Finance,” the “disclosure Dialogue Guidance for Promoting Sustainable Finance in Circular Economy,” Japan’s J-Credit certification programme, the FY2020 Environmental Information Infrastructure Development Project on mandatory carbon reporting, and government studies on energy-conservation programmes—clearly identifying the content, timing and responsible ministries for each. The company also explains how it lobbies: it sits on ministry-led study groups, serves on the TCFD Consortium Planning Committee, acts as secretariat for transition-finance projects, is “commissioned by the Agency for Natural Resources and Energy” to carry out surveys, and submits formal recommendations and questionnaires to the Ministry of the Environment, METI and the Financial Services Agency, naming each public body it targets. Finally, it spells out what it wants to achieve, such as embedding transparency and reliability requirements in the Climate Transition Finance guidelines, “expanded adoption of renewable-energy power generation equipment at small and medium-sized enterprises and households,” developing sector transition roadmaps, and guiding investors’ ESG practices, stating it supports the relevant policies “with no exceptions.” This level of detail across policy scope, engagement methods and desired results demonstrates a high level of transparency in its climate-related lobbying disclosures.	A