Sumitomo Chemical Co Ltd

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Strong	Sumitomo Chemical Co Ltd has provided robust transparency around its climate-policy lobbying activities. It names the specific policy frameworks it engaged on—namely the IFRS Foundation’s “公開草案（全般的な要求事項の公開草案、気候関連開示事項の公開草案）” for non-financial disclosure standards and Japan’s “エネルギーの使用の合理化等に関する法律”—confirming these as the principal measures it addressed. The company details multiple lobbying mechanisms and targets, including participation as a committee member in the Ministry of Economy, Trade and Industry’s non-financial disclosure study group (“非財務情報の開示指針研究会”), direct submissions to the IFRS Foundation, and meetings with Japanese policy officials (“政策担当者”) regarding proposed subsidy application criteria for energy-efficient equipment. It also clearly articulates the outcomes sought: clarifying the estimation methodology and scope for Scope 3 GHG emissions and allowing flexible reporting timelines in the final IFRS S1 and S2 standards, and opposing a steep rise in energy-efficiency thresholds by proposing a more moderate increase for subsidy eligibility. This comprehensive naming of policies, explanation of how and whom it lobbied, and specification of precise policy objectives demonstrates a strong level of transparency in its climate lobbying.	3

Lobbying Governance

Overall Assessment	Comment	Score
Limited	Sumitomo Chemical Co Ltd articulates a public commitment to align its engagement activities with the goals of the Paris Agreement, stating that it “has a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement.” However, the company does not disclose any mechanisms for oversight, lacking details on who is responsible for reviewing lobbying alignment, no description of monitoring or management processes, and no named individual or formal body overseeing its policy engagement. We found no evidence of board sign-off, periodic reviews, or governance structures that would ensure its lobbying is consistent with its Paris Agreement pledge, indicating that while there is a broad policy statement, substantive governance elements are absent.	1