TDK Corp – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Strong	TDK discloses a structured process that ties its policy advocacy to its climate strategy and identifies clear oversight, indicating strong governance of both direct and indirect lobbying activities. The company states that it engages policy makers directly, noting that it "政府の大臣級及び環境政策セクションの担当者と情報・意見交換を行い、政策提言を実施しています", while most engagement is conducted through the trade association JEITA, where TDK serves as a steering-committee member. To keep these activities aligned, the company explains that the content of policy engagement "is regularly reported to the Executive Officer in charge of Sustainability" and, when necessary, "経営会議の審議や取締役会への報告も行い、弊社の環境戦略との整合性を確認". It further commits that "If there is a significant discrepancy … we will work with the organization to ensure consistency… including the possibility of withdrawing from the organization", demonstrating an escalation mechanism for misalignment with trade associations. This governance coverage extends globally, as overseas subsidiaries are managed "under the Sustainability Promotion HQ Safety & Environment Group" which "collects information" and coordinates "グローバルな政策エンゲージメント". However, the company does not disclose a publicly available, in-depth lobbying-alignment report or an independent audit, and it provides limited detail on the specific criteria or frequency of its reviews, so transparency remains weaker than the most comprehensive practices. View Sources	B

Overall Assessment

Analysis

Score

Strong

TDK discloses a structured process that ties its policy advocacy to its climate strategy and identifies clear oversight, indicating strong governance of both direct and indirect lobbying activities. The company states that it engages policy makers directly, noting that it "政府の大臣級及び環境政策セクションの担当者と情報・意見交換を行い、政策提言を実施しています", while most engagement is conducted through the trade association JEITA, where TDK serves as a steering-committee member. To keep these activities aligned, the company explains that the content of policy engagement "is regularly reported to the Executive Officer in charge of Sustainability" and, when necessary, "経営会議の審議や取締役会への報告も行い、弊社の環境戦略との整合性を確認". It further commits that "If there is a significant discrepancy … we will work with the organization to ensure consistency… including the possibility of withdrawing from the organization", demonstrating an escalation mechanism for misalignment with trade associations. This governance coverage extends globally, as overseas subsidiaries are managed "under the Sustainability Promotion HQ Safety & Environment Group" which "collects information" and coordinates "グローバルな政策エンゲージメント". However, the company does not disclose a publicly available, in-depth lobbying-alignment report or an independent audit, and it provides limited detail on the specific criteria or frequency of its reviews, so transparency remains weaker than the most comprehensive practices.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	TDK offers only a basic view of its climate-policy lobbying. It does identify two specific Japanese statutes it supports—the Act on Promotion of Global Warming Countermeasures and the Act on Rationalization of Energy Use and Shift to Non-fossil Energy—indicating some transparency about the policy areas in which it is active. Beyond noting that it works through industry bodies such as JEITA and initiatives like RE100, however, the company does not explain the concrete methods it uses to influence policymakers or name the government departments or officials it engages. The disclosure is likewise high-level on objectives, limiting itself to broad corporate goals such as achieving net-zero CO₂ emissions by 2050 and encouraging renewable energy, without spelling out the specific legislative or regulatory outcomes it seeks. As a result, the company’s overall lobbying transparency remains limited.	D