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| Overall Assessment |
Comment |
Score |
| Limited |
Osaka Gas provides a basic, but not extensive, picture of its climate-policy lobbying. It clearly identifies the main regulation it engaged with—the Japanese “Act on Promotion of Global Warming Countermeasures” and the Ministry of the Environment’s 2018 draft environmental reporting guidelines—showing openness about the specific policies involved. The company explains that it lobbied the Ministry of the Environment by “専門的な観点から意見を述べる,” i.e. submitting technical opinions on how greenhouse-gas calculations should be performed, but it does not describe any additional channels such as formal consultations, letters or industry-association activity, so the range of mechanisms disclosed is narrow. Osaka Gas is also transparent about the single objective it pursued: it argued that “it is reasonable to calculate the amount of GHG emission reduced by reducing purchase amount of grid electricity using the CO2 emission coefficient of the marginal power source,” and notes that this proposal was incorporated into the draft guidelines, aligning its position with the Paris Agreement. Because the disclosure covers only one mechanism and one specific outcome, and references just one primary policy instrument, the company’s overall transparency on its climate lobbying remains limited.
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1
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| Overall Assessment |
Comment |
Score |
| Strong |
Osaka Gas has established a structured governance process for policy engagement by requiring that “any direct or indirect engagement activities that influence policy must be consistent with the strategies of the Group's business and climate change response,” and by mandating monthly Executive Board reviews in which “trends in policies relating to climate change and our direct and indirect engagement activities are reported and shared” with the President, Vice Presidents, Directors, and heads of business units. Further oversight is provided by the ESG Committee, chaired by the “Head of ESG Promotion (Vice President Executive Officer),” and its Environmental Subcommittee, which meet four and three times annually respectively to discuss “the trends of policies relating to climate change,” the Group’s business plans and results, and specialized research institute surveys, ensuring that policy engagement aligns with its Carbon Neutral Vision and 2030 Long-Term Management Vision. While these disclosures indicate robust mechanisms for monitoring and accountability, we found no evidence of a publicly available audit or dedicated report on climate lobbying alignment, nor any specified criteria for reassessing or exiting external associations whose lobbying positions may conflict with the company’s climate strategy.
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3
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