Korea District Heating Corp

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Strong	Korea District Heating Corp provides a solid level of detail on all key aspects of its climate-policy lobbying. It identifies two concrete policy frameworks it has engaged on—the Republic of Korea’s Emission Trading Scheme and the government’s “3rd National Climate Change Adaptation Measures (2021-2025)”—and links its involvement to earlier adaptation measure cycles, demonstrating clarity about the specific regulatory instruments under discussion. The company also spells out how it lobbies and whom it targets: it submitted formal requests to the Ministry of Environment, participated in “seminars, meetings, and public hearings hosted by government agencies,” and worked with law firms, climate experts and the Korea District Heating and Cooling Association to persuade officials, naming the Ministry of Environment as the principal policymaking audience. Finally, it is explicit about the policy changes it seeks, aiming for “free allocation of integrated energy” allowances, an “increase in the emission cap” that reflects business growth, recognition of extra allocations for high-efficiency facilities, and incentives such as suspending paid allocations, while on adaptation policy it expresses “Support with no exceptions.” By linking each lobbying activity to concrete desired regulatory outcomes and disclosing the mechanisms and governmental targets involved, the company demonstrates a high degree of transparency in its climate-related lobbying.	3

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Korea District Heating Corp discloses a structured process to keep its policy-related engagement aligned with its climate strategy, noting that it “carries out performance management based on the PDCA Cycle, centred on the Carbon Management Committee” and that the committee “manages the achievements … to maintain consistency between company-wide climate change strategies and engagement activities.” Oversight is clearly assigned, as “the head of each division holds meetings from time to time and reports the inspection results to the Committee twice a year,” and the committee updates the “2050 Carbon Management Strategy” annually, demonstrating an internal review mechanism. This indicates that a formal body is responsible for monitoring and adjusting external engagement so it supports the firm’s decarbonisation plan. However, the disclosure remains high-level: it does not specify whether the process explicitly covers direct lobbying with policymakers or indirect lobbying via trade associations, nor does it describe criteria for assessing or correcting misalignment with third-party positions. We found no evidence of a public lobbying-alignment audit or of actions such as engaging or exiting associations whose climate stances diverge from the company’s, so the transparency and scope of the governance framework appear limited beyond the internal review cycle.	2