SK Inc

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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
Strong	SK Inc. demonstrates a structured governance process for aligning its policy engagement and association involvements with its climate change strategy, with oversight by its Board of Directors, ESG Committee, and designated officers, yet it does not disclose a standalone climate-lobbying alignment report or third-party review. For government engagement, the company states that “the CEOs and CSOs of SK Group companies actively participate in the Social Value Committee, Environmental Business Committee, and Communication Committee to address common issues and find solutions related to government policies, including renewable energy procurement, carbon emissions allowances, and greenhouse gas reduction measures,” and affirms that “SK’s ESG, Legal, Corporate and Public Relationship (CPR), HR, and purchasing organizations 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.” At the board level, “through the ESG Committee under the board of directors, SK Inc. is responsible for determining how to respond to climate change, reviewing mid- to long-term strategies, approving major tasks, and managing and supervising implementation,” and it notes that “the ESG Committee receives reports on ESG and climate risk assessments from investment companies twice a year and holds decision-making authority on key matters.” In managing indirect lobbying, SK Inc. “operates a system to evaluate and manage the alignment of its association memberships with the company’s growth, sustainability, business ethics, fair trade, and compliance with the Paris Agreement,” requiring that “activities such as joining, withdrawing from, and making expenditures on annual fees and donations to associations require the cooperation and approval of the External Communication Officer, who reports directly to the CEO,” and outlining measures from “public statements on discrepancies” to “non-renewal or withdrawal from memberships.” We found no evidence of a publicly available audit or detailed report explicitly evaluating the alignment of its lobbying activities with its climate goals.	3