TOTO Ltd

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Moderate TOTO offers a moderate level of transparency around its climate-policy lobbying. It identifies two concrete policy initiatives it has worked on: the national “COOL CHOICE” energy-efficiency campaign and the Japanese CO2-emission-reduction programme that subsidises the renovation of homes with new water- and energy-saving equipment. While the company also references participation in the Ministry of Economy, Trade and Industry’s GX League, it does not spell out any distinct policy proposals associated with that forum. TOTO explains how it engages policymakers, stating that it directly submitted proposals on replacing old equipment with water-saving devices to government administrators, collaborated with its industry association to lodge a joint proposal, and attended events organised by the Ministry of the Environment, thereby revealing both direct and indirect lobbying channels and naming the Ministry as a specific target. The firm is similarly explicit about the outcome it sought and achieved: it wanted the official renovation policy to recognise and promote water-saving devices, and it supported this objective by developing and publicising a method for calculating the associated CO2-reduction benefits. However, beyond this single outcome and a general affirmation that it “supports all Japanese laws and regulations on CO2 emission reductions,” the company does not set out additional concrete legislative changes or quantitative goals, and some engagements (such as its role in the GX League) remain only broadly described. Taken together, the disclosures show clear but not comprehensive insight into what TOTO lobbies for, how it does so, and the specific policy changes it is pursuing. 2
Lobbying Governance
Overall Assessment Comment Score
Limited TOTO Ltd affirms that it has a “public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement”, which signals a policy-level recognition of aligning its advocacy with climate objectives. However, the company does not disclose any formal oversight body or named individual charged with overseeing this commitment, nor does it describe any monitoring or enforcement procedures for its direct or indirect lobbying activities. We found no evidence of any defined process for reviewing, approving, or aligning specific lobbying initiatives with its Paris-aligned policy, indicating only limited governance in this area. 1