Kumho Tire Co Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Limited	Kumho Tire discloses that it has set up ESG governance structures that touch on external policy engagement, but it provides only high-level descriptions rather than a defined lobbying-governance framework. The company states that an “ESG Committee was newly established under the Board of Directors, in order to manage and supervise ESG management at the board level and faithfully reflect environmental, social, and governance perspectives in major decision-making,” and that the committee “deliberates and decides on ESG management strategies, including the presentation of ESG management strategical directions, managing and monitoring progress on ESG management action tasks, and non-financial risk management.” It also reports that “Kumho Tire has established the ESG Part in the Strategic Planning & Innovation Team as an organization in charge of ESG management,” and that this team “integrated its strategies with ESG including climate issues pursuing the goals of Paris Agreement and stakeholders’ demands,” adding that it participates in alliances that “could influence policy.” These statements indicate that the board-level ESG Committee and internal ESG Team have some oversight over activities that may influence policy, signalling an intention to align such engagement with climate strategy. However, the disclosure does not spell out a specific process for reviewing or approving lobbying positions, makes no reference to monitoring or correcting the climate stances of trade associations, and does not identify any individual or committee explicitly responsible for ensuring alignment of direct and indirect lobbying with the company’s climate goals. Overall, the company describes general ESG oversight that touches on policy engagement, but we found no evidence of a detailed, formal governance process dedicated to climate-lobbying alignment, no mention of regular reviews or audits of lobbying activities, and no criteria for addressing misalignment; this indicates only limited governance. View Sources	D

Overall Assessment

Analysis

Score

Limited

Kumho Tire discloses that it has set up ESG governance structures that touch on external policy engagement, but it provides only high-level descriptions rather than a defined lobbying-governance framework. The company states that an “ESG Committee was newly established under the Board of Directors, in order to manage and supervise ESG management at the board level and faithfully reflect environmental, social, and governance perspectives in major decision-making,” and that the committee “deliberates and decides on ESG management strategies, including the presentation of ESG management strategical directions, managing and monitoring progress on ESG management action tasks, and non-financial risk management.” It also reports that “Kumho Tire has established the ESG Part in the Strategic Planning & Innovation Team as an organization in charge of ESG management,” and that this team “integrated its strategies with ESG including climate issues pursuing the goals of Paris Agreement and stakeholders’ demands,” adding that it participates in alliances that “could influence policy.” These statements indicate that the board-level ESG Committee and internal ESG Team have some oversight over activities that may influence policy, signalling an intention to align such engagement with climate strategy. However, the disclosure does not spell out a specific process for reviewing or approving lobbying positions, makes no reference to monitoring or correcting the climate stances of trade associations, and does not identify any individual or committee explicitly responsible for ensuring alignment of direct and indirect lobbying with the company’s climate goals. Overall, the company describes general ESG oversight that touches on policy engagement, but we found no evidence of a detailed, formal governance process dedicated to climate-lobbying alignment, no mention of regular reviews or audits of lobbying activities, and no criteria for addressing misalignment; this indicates only limited governance.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Kumho Tire offers some but not comprehensive insight into its climate-policy lobbying. It identifies two concrete policies—the Korea Emissions Trading Scheme and the Tianjin (China) pilot ETS—stating that it "has participated in the ETS from the first period to third period" and complied with associated reporting and allocation rules, which provides a reasonable level of specificity about the frameworks it engages with. The company outlines general methods of engagement, noting that it "responds to climate change by complying with applicable laws pertaining to [the] emissions trading scheme … and cooperating with the government’s low carbon green growth policy," and that it submits verified GHG data annually and works through bodies such as the UN Global Compact and the Korea Tire Manufacturers Association; however, it does not name the particular ministries, regulators, or individual decision-makers it approaches, so the exact lobbying channels and targets remain vague. On desired outcomes, Kumho Tire indicates it aims to keep its emissions "below the allocated emission permits every year" and to contribute to national net-zero goals, but it does not spell out any specific policy changes, amendments, or numeric ambitions it is pressing for. Overall, the disclosure shows limited transparency: it acknowledges the principal schemes it interacts with and gives a high-level description of how and why it engages, yet stops short of detailing concrete lobbying actions, specific interlocutors, or explicit policy objectives.	D