Mitsui OSK Lines Ltd – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Mitsui O.S.K. Lines discloses a defined internal structure for keeping its public-policy engagement consistent with its climate strategy, indicating moderate governance of climate-related lobbying. The company states that "????????????2021?4?1???????????????????????????????????????????????", demonstrating that a dedicated committee reviews all position statements for alignment with the Groups climate goals. It further explains that "?????????????????????????????????????????????????????????????????????????????????????????????????????", showing that both direct advocacy and information gathered via industry associations are channelled to the committee for consistency checks. Oversight responsibilities are clearly assigned: "The Group has established a management structure with the CEO as the decision maker", the "Chief Sustainability Officer (CSuO) oversees environmental initiatives", and the Sustainability Committee, chaired by the CFO, reports "to the Executive Committee and the Board of Directors as appropriate" while items of importance require Board approval. The company also affirms a "public commitment to conduct engagement activities in line with the goals of the Paris Agreement". These disclosures evidence a formal process, named senior oversight and coverage of both direct and indirect lobbying, which indicates strong intent to manage alignment. However, MOL does not disclose any detailed methodology or criteria used to test alignment, nor does it provide examples of correcting or withdrawing from trade bodies that hold conflicting climate positions, and there is no stand-alone public lobbying alignment report or third-party audit; therefore the transparency and demonstrable effectiveness of the process remain limited. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Mitsui O.S.K. Lines discloses a defined internal structure for keeping its public-policy engagement consistent with its climate strategy, indicating moderate governance of climate-related lobbying. The company states that "????????????2021?4?1???????????????????????????????????????????????", demonstrating that a dedicated committee reviews all position statements for alignment with the Groups climate goals. It further explains that "?????????????????????????????????????????????????????????????????????????????????????????????????????", showing that both direct advocacy and information gathered via industry associations are channelled to the committee for consistency checks. Oversight responsibilities are clearly assigned: "The Group has established a management structure with the CEO as the decision maker", the "Chief Sustainability Officer (CSuO) oversees environmental initiatives", and the Sustainability Committee, chaired by the CFO, reports "to the Executive Committee and the Board of Directors as appropriate" while items of importance require Board approval. The company also affirms a "public commitment to conduct engagement activities in line with the goals of the Paris Agreement". These disclosures evidence a formal process, named senior oversight and coverage of both direct and indirect lobbying, which indicates strong intent to manage alignment. However, MOL does not disclose any detailed methodology or criteria used to test alignment, nor does it provide examples of correcting or withdrawing from trade bodies that hold conflicting climate positions, and there is no stand-alone public lobbying alignment report or third-party audit; therefore the transparency and demonstrable effectiveness of the process remain limited.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Mitsui O.S.K. Lines provides a high degree of clarity around every aspect of its climate-policy engagement. It names a suite of specific measures on which it has tried to shape the rule-making process, including the International Maritime Organization’s "monitoring, reporting and verification (MRV) of CO2 emissions" system, the development of the IGF code for LNG-fuelled ships, and the design of market-based measures such as the "EEXI" and "CII" requirements that sit within the MARPOL framework. The company also discloses how it channels its views: it participates in the Japanese Shipowners’ Association working group that meets the Ministry of Land, Infrastructure, Transport and Tourism, serves on Japan Ship Technology Research Association committees, and submits positions to the IMO’s Marine Environment Protection Committee via the International Chamber of Shipping, in addition to direct input at IMO technical meetings. Finally, MOL is explicit about what it wants these interventions to achieve—urging that MRV rules be refined so they do not become "an additional burden for the shipping industry," calling for LNG-ship regulations that are not so strict that they deter newbuilds, and backing the early introduction of economic incentives that promote low-carbon fuels through a market-based mechanism. By combining detailed policy references, clearly identified channels and targets, and articulated policy objectives with supporting rationale, the company demonstrates comprehensive transparency on its climate-related lobbying activities.	A