Mitsubishi UFJ Financial Group Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Mitsubishi UFJ Financial Group discloses a governance structure that touches directly on how its climate-related lobbying is overseen and aligned, but the information remains high-level and largely process-oriented. The company states that it will conduct “direct and indirect lobbying and partner with governments/public sector toward net-zero transitions” and pledges to “ensure alignment between client/portfolio companies’ lobbying and initiatives for net zero,” signalling an explicit policy intent to keep advocacy consistent with its climate strategy. Oversight is assigned to named bodies: the disclosure notes that “the Sustainability Committee, which is a sub-committee formed under the Executive Committee and is chaired by the Chief Sustainability Officer, regularly deliberates policies… and monitors the progress,” while “any updates to this policy are subject to approval by the Sustainable Engagement Meeting, which the Stewardship Committee monitors on a regular basis,” and ultimate supervision sits with “the Board of Directors.” For indirect lobbying, MUFG explains that it “shares the content discussed in committees internally, particularly ensuring alignment between the policies of industry associations related to climate change response and MUFG’s own policies. In cases of discrepancies, adjustments are made through discussions in various committees,” indicating an internal mechanism to check and correct trade-association positions. However, the company does not disclose a public climate-lobbying alignment report, gives no details of systematic reviews or third-party audits of its advocacy, and provides no examples of modifying or terminating memberships or of specific procedures governing its own direct lobbying activities. Consequently, while MUFG demonstrates a stated policy, a named oversight structure and some process for aligning industry-association positions, the depth, frequency and transparency of monitoring remain unclear. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Mitsubishi UFJ Financial Group discloses a governance structure that touches directly on how its climate-related lobbying is overseen and aligned, but the information remains high-level and largely process-oriented. The company states that it will conduct “direct and indirect lobbying and partner with governments/public sector toward net-zero transitions” and pledges to “ensure alignment between client/portfolio companies’ lobbying and initiatives for net zero,” signalling an explicit policy intent to keep advocacy consistent with its climate strategy. Oversight is assigned to named bodies: the disclosure notes that “the Sustainability Committee, which is a sub-committee formed under the Executive Committee and is chaired by the Chief Sustainability Officer, regularly deliberates policies… and monitors the progress,” while “any updates to this policy are subject to approval by the Sustainable Engagement Meeting, which the Stewardship Committee monitors on a regular basis,” and ultimate supervision sits with “the Board of Directors.” For indirect lobbying, MUFG explains that it “shares the content discussed in committees internally, particularly ensuring alignment between the policies of industry associations related to climate change response and MUFG’s own policies. In cases of discrepancies, adjustments are made through discussions in various committees,” indicating an internal mechanism to check and correct trade-association positions. However, the company does not disclose a public climate-lobbying alignment report, gives no details of systematic reviews or third-party audits of its advocacy, and provides no examples of modifying or terminating memberships or of specific procedures governing its own direct lobbying activities. Consequently, while MUFG demonstrates a stated policy, a named oversight structure and some process for aligning industry-association positions, the depth, frequency and transparency of monitoring remain unclear.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Strong	Mitsubishi UFJ Financial Group provides a solid level of transparency on its climate-policy advocacy. It names a number of identifiable public-policy initiatives it works on, including Japan’s Green Transformation Basic Policy, the Just Energy Transition Partnerships in Indonesia and Vietnam, and the Asia Energy Transition Initiative and its Asia Transition Finance Study Group, showing that its lobbying is directed to concrete government programmes rather than only to voluntary industry standards. The group also sets out multiple, specific ways it seeks to influence decision-makers and identifies who those decision-makers are. It describes preparing Transition Whitepapers that are “communicated to policymakers in Japan and abroad,” sitting on committees convened by Japan’s Ministry of Economy, Trade and Industry and the Financial Services Agency, chairing the Transition Finance Working Group of the Net-Zero Banking Alliance, and engaging directly with the governments of Vietnam and Thailand as well as the Asian Development Bank during JETP discussions and COP side-events. Finally, MUFG explains the outcomes it wants these efforts to deliver: phasing-out coal financing for OECD borrowers by 2030 and for non-OECD borrowers by 2040, tripling global renewable-energy deployment by 2030 in line with the COP28 target, and expanding blended-finance and transition-finance frameworks so Asian economies can retire high-emitting assets sooner. Together, these disclosures give a clear picture of what the group is trying to achieve, how it acts, and the specific policy arenas it targets.	B