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| Overall Assessment |
Comment |
Score |
| Strong |
Pan Ocean Co. Ltd provides a detailed and transparent account of its climate-policy lobbying activities. It discloses engagement with three specific IMO measures—the IMO’s technical measure regulation, the Energy Efficiency Existing Ship Index (EEXI), and the Carbon Intensity Indicator (CII)—explaining the extension of EEXI to existing ships and the implications of CII ratings. The company clearly outlines its mechanisms, stating “Pan Ocean is attending this meeting as a representative of the shipping sector,” by first participating in expert preparatory meetings and then engaging in discussions at the IMO’s Marine Environment Protection Committee. It also specifies its policy goals, endorsing the GHG reduction framework and calling for full compliance with EEXI and CII requirements, stating its position as “Support with no exceptions” and aiming “to actively respond to climate change.” This combination of named policies, specified engagement channels, targeted policymaking body, and clearly defined outcomes demonstrates a strong level of transparency around its climate lobbying efforts.
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3
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| Overall Assessment |
Comment |
Score |
| Limited |
Pan Ocean reports that “all of Pan Ocean's climate change-related engagement activities are conducted through the Maritime Strategy Team, a department in charge of maintaining consistency and alignment with the strategy” and reiterates that its “dedicated Marine Environment Team” carries out external climate engagement “to ensure consistency and alignment with the strategy”, demonstrating that a specific internal team is tasked with checking whether the company’s advocacy activities fit its carbon-reduction plan. The company also says it “strictly prohibits any form of direct or indirect political contributions,” showing a basic control on political influence. Nevertheless, the disclosure does not describe a formal policy or procedure for reviewing lobbying positions, provides no detail on how indirect lobbying through trade associations is monitored, and does not identify any board committee or senior executive with oversight of lobbying alignment; additionally, it confirms “No” public commitment to align engagement with the Paris Agreement. This indicates only a limited, departmental-level process rather than a comprehensive governance framework for climate-related lobbying.
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1
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