SK Inc

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Strong SK Inc provides a solid level of transparency around its climate-policy lobbying. It identifies two concrete regulatory instruments it has engaged on—the Korean renewable electricity Power Purchase Agreement framework, including the “Notification on Direct Power Transactions by Renewable Energy Electricity Suppliers (Notification No. 2022-145, September 2022),” and the national “Korea Emissions Trading System (K-ETS).” The company also gives considerable detail on how and where it lobbies. It describes participation in a “corporate conference in August 2021” and a December 2021 “meeting with the Minister of Trade, Industry and Energy,” a “meeting between the Ministry of Environment’s Climate Strategy Division and businesses to promote the adoption of renewable energy” on 13 October 2022, direct proposals sent to the Ministry of Trade, Industry and Energy and KEPCO, and “active participation in government-led public hearings, seminars, and other events” on the K-ETS—clearly naming both the mechanisms (conferences, meetings, public hearings, written proposals) and the government bodies targeted. The desired policy outcomes are also spelled out: the company seeks to amend the PPA regime by “implementing REC weight for PPA market promotion,” “applying varied allocation factors to renewable-energy purchasing companies,” “providing incentives for PPA transactions (government subsidies, tax benefits, etc.),” and removing barriers such as the 1 MW threshold and additional network fees; it further states it “supports [K-ETS] with minor exceptions” and wants its smooth operation. By disclosing the policies, the channels and targets of engagement, and multiple specific changes it is advocating, SK Inc demonstrates a strong degree of openness about its climate-related lobbying activities. 3
Lobbying Governance
Overall Assessment Comment Score
Moderate SK Inc. discloses several mechanisms aimed at keeping its policy engagement aligned with its climate objectives, indicating a moderate level of lobbying governance. The company states that "SKs ESG, Legal, Corporate and Public Relationship (CPR)operate a process to identify, prevent, and evaluate environmental issues such as policies and laws in advance under the company-wide integrated risk management system," showing that at least some internal process exists to screen direct engagement for climate consistency, and it adds that CEOs and CSOs "regularly participate in the Social Value Committee and the Environmental Business Committee, and discuss common issues and solutions at the group level related to government policies." For indirect lobbying, it provides more concrete controls: "SK Inc. operates a system to evaluate and manage the alignment of its association memberships withcompliance with the Paris Agreement," explaining that joining or renewing memberships "require the cooperation and approval of the External Communication Officer, who reports directly to the CEO," and where misalignment is found the company may issue "public statements on discrepancies discussions on modifying the associations stance non-renewal or withdrawal from memberships." This named officer oversight and the listed corrective actions indicate active governance of trade-association lobbying. Oversight at board level is also referenced, with the ESG Committee "managing/supervising climate change issues" and holding "decision-making authority on key matters," although the disclosures do not explicitly tie this committee to monitoring lobbying positions. The company makes a "public commitment to conduct [its] engagement activities in line with the goals of the Paris Agreement," yet we found no evidence of a routine, formal review of the companys own direct lobbying positions, including a dedicated climate-lobbying alignment report. Consequently, while SK Inc. shows a clear policy, named oversight and a structured process for monitoring and, if necessary, exiting misaligned associations, the disclosure around direct lobbying monitoring is limited, and the absence of a published alignment review keeps the governance at a moderate rather than strong level. 2