LOTTE Fine Chemical Co Ltd

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Limited	LOTTE Fine Chemical provides only limited insight into its climate-policy lobbying. It does identify one specific measure it engages on – the Korea Emissions Trading System (K-ETS) established under the Act on Allocation and Trading of Greenhouse Gas Emission Rights – and notes its status as an allocation-targeted company since the scheme’s first phase, but it does not mention any additional climate-related laws or regulations. The company indicates that it offers “industry-specific suggestions and opinions to policymakers” and maintains “cooperative relationships with government officials” to influence ETS rules, suggesting direct engagement, yet it does not clarify the precise channels employed (such as formal consultations, letters, or meetings) nor name the government bodies or officials approached. On intended outcomes, it broadly states that it seeks adjustments to the ETS so that emission caps and allowance allocations “do not hinder the growth of the chemical sector” and that it wishes to keep compliance costs manageable while still helping the government meet its climate objectives; however, it does not spell out the concrete policy changes or quantitative targets it is pressing for. Because the disclosures cover only one policy, describe mechanisms and targets in general terms, and articulate desired results only at a high level, the overall transparency of the company’s climate-lobbying activities remains limited.	1

Lobbying Governance

Overall Assessment	Comment	Score
Limited	Lotte Fine Chemical provides only high-level statements that its "engagement activities are consistent with [its] overall climate change strategy" and confirms it has "a public commitment or position statement to conduct [its] engagement activities in line with the goals of the Paris Agreement," indicating an intention to align advocacy with climate goals. It states that "an ESG committee is formed under the board of directors of listed affiliates, and through this, the company's ESG management promotion is systematically managed" and that ESG performance is tied to CEO evaluation, suggesting some board-level oversight of ESG-related engagement. However, the disclosure does not explain how this committee reviews or approves lobbying, gives no detail on any monitoring or audit of direct or indirect lobbying positions, and offers no examples of assessing or addressing misalignment with trade associations. We found no evidence of a dedicated lobbying-governance framework, no description of specific procedures, and no identification of individuals responsible for lobbying alignment. Overall, the information points to limited but stated oversight intentions, while concrete governance mechanisms for lobbying alignment remain undisclosed.	1