ITOCHU Corp – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	ITOCHU has implemented a structured process to align its climate positions within industry associations, requiring that “we report any new policies of various industry associations to the head of our relevant industry-related departments or functional departments and obtain their approval,” and where there is a policy gap, that “we report to the CAO, who chairs our Sustainability Committee, and the Sustainability Committee and other committees decide to review our company policies in line with new policies of industry associations.” This demonstrates a concrete mechanism for governing indirect lobbying. Oversight is assigned to the CAO, described as the “Representative Director responsible for climate change–related issues,” who chairs the Sustainability Committee and “is responsible for presenting and reporting to the Board of Directors the matters duly deliberated and decided at the Sustainability Committee,” ensuring executive-level review. While ITOCHU has a public commitment to conduct its engagement in line with the Paris Agreement, there is no disclosure of a parallel process for managing or monitoring its direct lobbying activities against its climate policy, and we found no evidence of a specific procedure for direct lobbying oversight. View Sources	C

Overall Assessment

Analysis

Score

Moderate

ITOCHU has implemented a structured process to align its climate positions within industry associations, requiring that “we report any new policies of various industry associations to the head of our relevant industry-related departments or functional departments and obtain their approval,” and where there is a policy gap, that “we report to the CAO, who chairs our Sustainability Committee, and the Sustainability Committee and other committees decide to review our company policies in line with new policies of industry associations.” This demonstrates a concrete mechanism for governing indirect lobbying. Oversight is assigned to the CAO, described as the “Representative Director responsible for climate change–related issues,” who chairs the Sustainability Committee and “is responsible for presenting and reporting to the Board of Directors the matters duly deliberated and decided at the Sustainability Committee,” ensuring executive-level review. While ITOCHU has a public commitment to conduct its engagement in line with the Paris Agreement, there is no disclosure of a parallel process for managing or monitoring its direct lobbying activities against its climate policy, and we found no evidence of a specific procedure for direct lobbying oversight.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	ITOCHU’s climate-lobbying disclosures provide only limited transparency. The company does name two identifiable policies it has engaged on – the EU Carbon Border Adjustment Mechanism and the planned expansion of the EU Emissions Trading System – showing some clarity about the issues it follows. However, it offers very little detail on how it seeks to influence those or any other measures. The only mechanism it cites is that it is "actively involving and making proposals at the public-private councils" and participating in initiatives such as the GX League and the Japan Climate Initiative; no information is given on whether this means letters, meetings, consultations or which government departments or legislators are approached. Likewise, the company discusses broad aims such as advancing carbon-credit trading, supporting CCS deployment and helping Japan reach carbon-neutrality, but it does not spell out any precise legislative changes, subsidy levels or regulatory amendments it is pursuing. As a result, while ITOCHU acknowledges some engagement with specific climate policies, it does not reveal the targets, methods or concrete outcomes it seeks, leaving most of its lobbying activity opaque.	D