MS&AD Insurance Group Holdings Inc

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	MS&AD Insurance Group provides a detailed and wide-ranging picture of its climate-policy advocacy. It identifies several concrete policy files it works on, including "国土強靭化と地方創生に資するグリーンインフラの活用" (use of green infrastructure for national resilience), the promotion of "脱炭素政策" with the Ministry of Education, participation in drafting Japanese climate-related disclosure standards and the ISSB exposure draft, support for the government’s "地球観測の推進戦略", and engagement in "日本での排出権取引制度（GXリーグへの賛同と協議参加）". The company also lays out the channels it uses and the government bodies it targets: it has served as secretary of the Green Infrastructure Public-Private Partnership Platform under the Ministry of Land, as a committee member in Ministry of Education climate discussions, "submitted public comments" to the ISSB, sits on the Earth Observation Promotion Subcommittee under the Council for Science and Technology Policy, and has exchanged information with the Ministry of Economy, Trade and Industry while the GX League was being established. Finally, MS&AD is explicit about what it wants these efforts to achieve—expanding green infrastructure for adaptation and regional revitalisation, stimulating university research that accelerates regional decarbonisation, broadening the use of earth-observation data for climate resilience, and advancing an emissions-trading scheme it "supports with no exceptions" and states is aligned with the Paris Agreement. By naming the policies, the governmental counterparts and the precise policy outcomes it pursues, the company demonstrates a high level of transparency in its climate-related lobbying.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	MS&AD Insurance Group Holdings Inc has established a structured process to ensure its external engagement activities are consistent with its climate commitments, particularly through indirect channels like trade associations. As the company explains, “気候変動に関する活動は、エンゲージメント活動は、サステナビリティ所管部署に報告され、整合性を確認している,” and for its “memberships of industry associations and outside initiatives,” “the status of their membership and activities are managed by the line of control, and important information is reported to the director in charge.” These engagement statuses are subject to escalation, with “material matters … reported to the officer in charge,” and addressed through further discussions “to confirm consistency with our policy.” Oversight of these external engagements is integrated into its sustainability governance, with the Sustainability Committee “headed by the Group CSuO” reviewing and reporting on significant matters. However, we found no evidence of a comparable governance process for direct lobbying of policymakers, nor any published audit or third-party assessment of its climate-related lobbying activities, indicating that the framework is focused on indirect engagement and lacks transparency and formal alignment mechanisms for direct lobbying.	2