INFRONEER Holdings Inc

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Moderate	INFRONEER Holdings discloses a reasonable amount of detail about its climate-related lobbying. It identifies one concrete policy instrument it has tried to shape – Japan’s Green Purchasing Law and related procurement rules for public works – and explains that the initiative is aimed at encouraging “low-carbon innovation and R&D” through wider use of recycled aggregate concrete. The company also outlines how it engages: it submitted a formal FY2022 budget request to the Tokyo Metropolitan Government and lobbied via its position as chair of the Environmental Committee of the Tokyo Construction Industry Association, clearly naming both the mechanism and the policymaking target. Finally, it is explicit about what it wants to achieve, namely an expansion of recycled aggregate concrete in public works and the relaxation of cost and regional restrictions that currently limit such procurement. Together, these disclosures provide moderate transparency, though they focus on a single policy area and describe only two specific engagement methods.	2

Lobbying Governance

Overall Assessment	Comment	Score
Limited	Infroneer Holdings Inc states that it “has a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement,” indicating a willingness to align its advocacy with global climate objectives. However, the company does not disclose any internal governance mechanisms for lobbying—there is no description of who oversees or reviews its lobbying activities, no process for monitoring direct or indirect lobbying alignment, and no named individual, committee, or formal body responsible for ensuring its engagement remains consistent with its climate commitments.	1