Mitsui Fudosan Co Ltd

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Strong	Mitsui Fudosan discloses a considerable amount of detail about the substance and objectives of its climate-policy lobbying. It identifies several specific instruments it has engaged on, including the “Tokyo Metropolitan Government Mandatory Total Emissions Reduction and Cap-and-Trade Program,” the “building environment plan system of the Tokyo Metropolitan Environmental Security Ordinance,” and the national “Act on the Improvement of Energy Consumption Performance of Buildings.” The company explains that it has “cooperat[ed] with the process for formulating policies, such as directly submitting opinions on the Tokyo Metropolitan Government Mandatory Total Emissions Reduction and Cap-and-Trade Program” and has “submitt[ed] opinions on the formulation of revised energy-saving standards,” thereby revealing at least one clear lobbying mechanism and the governmental bodies it addresses. Mitsui Fudosan is also explicit about the changes it seeks: it has asked for “relaxation of the floor area ratio for special areas to align with reduced energy usage,” “amendments to the energy-saving calculation standards to ensure accurate performance reflection,” revisions to the “designation rules for ‘top level Facilities,’” and “realistic specifications suitable for buildings and residences” under the building energy-efficiency law. This level of specificity on policies and desired legislative outcomes demonstrates strong transparency, even though it provides less detail on the full range of mechanisms beyond direct submission of opinions.	3

Lobbying Governance

Overall Assessment	Comment	Score
Limited	Mitsui Fudosan’s disclosures indicate a limited governance framework for its climate-related lobbying activities, centered on participation in external initiatives rather than an internal oversight structure. It highlights a “public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement,” and explains that “through the activities of the Japan Climate Initiative (JCI), the Japan Climate Leaders’ Partnership (JCLP), and the Japan Business Federation (Keidanren), Mitsui Fudosan is making efforts to achieve its established goals.” The company states “we participate in each organization and, on behalf of the real estate industry, proactively speak about current issues, the policies that the industry as well as Japan must undertake to reduce greenhouse gases, and about the way forward.” However, we found no evidence of an internal policy or process for reviewing, approving, or monitoring its direct or indirect lobbying activities; no individual or committee is named to oversee alignment; and no details are provided on how it ensures its advocacy through industry associations remains consistent with its climate commitments.	1