Mitsui OSK Lines Ltd

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Mitsui O.S.K. Lines (MOL) has demonstrated a comprehensive level of transparency in disclosing its climate lobbying activities. The company has clearly named specific climate policies it has engaged with, such as the "monitoring, reporting and verification (MRV) of CO2 emissions" for the shipping industry, the "Energy Efficiency Design Index (EEDI)," and the "Ship Energy Efficiency Management Plan (SEEMP)," all under the International Maritime Organization (IMO) framework. Additionally, MOL has disclosed its participation in the Japan Ship Technology Research Association (JSTRA) committee and its engagement with the Ministry of Land, Infrastructure, Transport and Tourism of Japan, providing detailed information about its involvement in shaping these policies. MOL has also been transparent about its lobbying mechanisms, including its participation in the Japanese Shipowners' Association's GHG Taskforce, which consolidates opinions and submits them to the IMO's Marine Environment Protection Committee via the International Chamber of Shipping (ICS). Furthermore, the company has disclosed its engagement with the Ministry of Land, Infrastructure, Transport and Tourism of Japan and its participation in committees established by JSTRA to submit industry perspectives to the IMO. MOL has also been clear about the specific outcomes it seeks, such as advocating for the early introduction of a system to promote the adoption of low-carbon fuels in the international maritime sector through economic incentives (MBM). The company explicitly supports measures to encourage the transition from fossil fuels to renewable energy-derived low-carbon fuels, aiming to achieve actual GHG emission reductions. It has also provided a rationale for its positions, such as ensuring that rules for LNG-fueled ships are not overly conservative to avoid discouraging shipowners from adopting such vessels. This level of detail and clarity illustrates MOL's comprehensive approach to disclosing its climate lobbying efforts and objectives.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	The company demonstrates a strong governance process for climate lobbying alignment, as evidenced by the establishment of a "Chief Environment and Sustainability Officer" who chairs the "Environmental Sustainability Committee." This committee is explicitly tasked with ensuring the alignment of the company's climate change strategy with its engagement activities, including both direct and indirect lobbying efforts. The committee "deliberates, establishes, and checks" the company's activities related to climate change strategy, and collects information from "related industry associations" to evaluate the "impact and integrity" of these activities in relation to its environmental strategy. Oversight and alignment are further reinforced through reporting mechanisms to the Environmental Sustainability Committee, which monitors and ensures alignment. Additionally, the company engages with "overseas industry groups" and gathers information through "Japanese Shipowners' Association (JSA)" and "Japan Ship Technology Research Association (JSTRA)," demonstrating efforts to align indirect lobbying activities with its climate strategy. These processes, overseen by the Environmental Sustainability Committee, include mechanisms for monitoring and reporting, indicating a robust governance structure. However, other evidence fails to disclose governance processes specifically related to climate lobbying alignment, focusing instead on general climate governance, risk management, and GHG reduction strategies, which do not meet the criteria for lobbying governance. Despite this, the detailed governance structure provided in the first evidence indicates strong governance.	3