Kumho Petrochemical Co Ltd

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Moderate	Kumho Petrochemical discloses its engagement with the 4th phase of the South Korean emission trading system, specifically advocating for the relaxation of carryover restrictions, demonstrating clarity about the policy it lobbies. It explains its lobbying mechanism through participation in “advanced conferences on emission trading hosted by the South Korean Ministry of Environment and other relevant public institutions,” where it has “continuously advocated for the relaxation of the carryover restrictions on emission permits.” The company is also explicit about the outcomes it seeks: easing those carryover restrictions, preparing for potential industry shocks from a sharp decline in permit supply, ensuring smoother implementation of the emission trading system, and facilitating efficient achievement of greenhouse gas reduction targets during the 4th phase, thereby outlining multiple concrete policy changes it supports.	2

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Kumho Petrochemical Co Ltd reports that it “maintain and manage various consultative bodies to maintain consistency in various climate change engagement and enterprise-wide climate change strategies,” with these bodies producing “quarterly results that check progress on implementation objectives” which are “reported to the CEO and the ESG Committee of the Board.” The company also affirms a “public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement.” While this structure shows formal oversight and regular review cycles, we found no evidence of processes for aligning specific lobbying efforts—whether direct advocacy or via trade associations—and no dedicated public affairs role beyond the ESG Committee is identified as overseeing lobbying alignment.	2