Kansai Electric Power Co Inc/The

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Limited	Kansai Electric Power Co. provides only limited transparency on its climate-policy lobbying. It names one specific initiative—the Japanese “Green Transformation League” emissions-trading system—placing that engagement within the broader category of “carbon pricing, taxes and subsidies” and declaring its “support with no exceptions,” but other references to nuclear, hydrogen or CCUS policy remain too general to identify particular laws or regulations. The company does describe more than one method of engagement, stating that it has “submitted written comments on the rules and regulations of this system,” “directly consulted with policy makers,” and participated in working groups such as the Atomic Energy Association, and it identifies some targets, including the Nuclear Energy Subcommittee under the Ministry of Economy, Trade and Industry. However, the outcomes it seeks are articulated only at a high level: it wants the Green Transformation League to “correctly and fairly evaluate companies that are making progressive decarbonization efforts,” while broader objectives such as reaching carbon neutrality or expanding offshore wind are presented as corporate aspirations rather than specific legislative changes. Because the disclosure pinpoints just one climate policy, offers only partial detail on lobbying channels and targets, and sets out only a single concrete policy outcome, the overall level of transparency remains limited.	1

Lobbying Governance

Overall Assessment	Comment	Score
Limited	Kansai Electric Power discloses only limited information on how it governs the alignment of its policy engagement with its climate strategy. It states that it has "a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement" and repeats that it "ensure[s] that [external engagement activities] are reflected in our business strategies," indicating an intention to align lobbying with climate goals. The company also describes an overarching compliance structure – the newly created "Compliance Promotion Headquarters" led by a "Chief Compliance Officer (CCO)" and reporting to the "Compliance Committee" – but the disclosure merely explains that the unit "provides training for compliance, encourages compliance with laws and regulations" and does not specify any procedure for reviewing, approving, or correcting direct or trade-association lobbying positions. Apart from the high-level pledge, we found no evidence of a systematic monitoring process, no discussion of trade-association reviews, and no explicit identification of a board committee or executive who checks whether lobbying aligns with the Paris Agreement. This indicates only limited governance of climate-related lobbying activities.	1