ENEOS Holdings Inc

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	ENEOS Holdings discloses climate-policy lobbying in considerable depth. It names a broad suite of specific policies it engages on, including Japan’s “Strategic Roadmap for Hydrogen and Fuel Cells,” the “Basic Hydrogen Strategy,” the government’s long-term CCS roadmap, design proposals for the Green Transformation emissions-trading scheme (GX-ETS), elements of the Sixth Strategic Energy Plan on CCS and synthetic fuels, and initiatives under the GX League chaired by the Prime Minister. The company also explains how it seeks to influence these measures, describing direct participation in bodies such as the Council for a Strategy for Hydrogen and Fuel Cells, the Public-Private Council to Promote Sustainable Aviation Fuel, the Carbon Recycling Roadmap Study Group, and the GX Implementation Council, as well as advocacy through its leadership roles in Keidanren and the Petroleum Association of Japan. Specific targets—METI, the Ministry of the Environment, JOGMEC and other national and local governments—are consistently identified, and mechanisms such as formal council membership, public-private feasibility studies, and written policy recommendations are set out. ENEOS is equally clear about the outcomes it wants: it supports a “baseline-and-credit” voluntary emissions-trading system instead of a carbon tax, seeks to “contribute to the expansion of FCVs and the early establishment of an independent hydrogen station business,” aims to start commercial CCS operations by 2030 and reach 20 Mt of capacity by 2040, and pursues policy support for domestically produced SAF and synthetic fuels, all in service of achieving “a decarbonized society and net-zero greenhouse gas emissions by 2050.” The combination of detailed policy references, clearly described engagement channels and targets, and explicit, measurable lobbying objectives demonstrates a high level of transparency across all dimensions of its climate-related lobbying.	4

Lobbying Governance

Overall Assessment	Comment	Score
Limited	ENEOS Holdings Inc discloses that it “is involved with and contributes to the formulation of policy recommendations by actively participating in government initiatives, as well as economic organizations and trade associations,” and notes that “through collaboration and advocacy with these government bodies and trade associations, we are working to ensure that policy, technological innovation, the orientation of society and customer needs are aligned toward the achievement of carbon neutrality by 2050.” It also confirms a public position to conduct its engagement in line with the Paris Agreement, stating “Yes” when asked if it has “a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?” While these statements reflect a commitment to align lobbying activities with its climate goals, the company does not disclose any formal governance process, such as a review or monitoring procedure, nor does it identify a specific individual or committee responsible for overseeing its direct or indirect lobbying efforts, and it provides no criteria for ensuring trade association positions are consistent with its carbon neutrality objectives.	1