SK Telecom Co Ltd – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	SK Telecom discloses a structured internal process that links climate-related engagement activities to board-level oversight, indicating more than a minimal approach to lobbying governance. The company states that the “ESG Initiative Group, as the operational body, deliberates on all matters related to the environment, energy, and greenhouse gases, including engagement activities and the overall climate strategy, to ensure consistency” and that it “continuously monitors and evaluates its external participation activities to ensure alignment with its environmental commitments and global climate goals, including those outlined in the Paris Agreement.” When misalignments are found, “the ESG Initiative Group conducts a thorough review and reports its findings to the CLO, who then determines next steps,” after which the findings are escalated to “the CEO and the ESG Committee for further deliberation.” Oversight responsibility is clearly assigned: “The CLO assesses the impacts… and decides whether to take further action, subsequently reporting these findings to the CEO and the ESG Committee,” while the ESG Committee of the Board “finalizes decisions” on key issues. This chain of monitoring, review, and board sign-off demonstrates both a policy and a concrete mechanism for keeping engagement activities aligned with climate strategy, and it names the specific bodies (ESG Initiative Group, CLO, CEO, ESG Committee) that carry that oversight. However, the disclosures do not provide evidence of a stand-alone lobbying-alignment audit, make no mention of procedures that explicitly differentiate between direct company lobbying and indirect lobbying via trade associations, and give no examples of correcting or exiting associations whose positions conflict with SK Telecom’s climate goals. The process therefore suggests moderate governance, with clear oversight and a stated alignment review, but without the detailed coverage and public reporting that would demonstrate a stronger, more comprehensive climate-lobbying governance system. View Sources	2

Overall Assessment

Analysis

Score

Moderate

SK Telecom discloses a structured internal process that links climate-related engagement activities to board-level oversight, indicating more than a minimal approach to lobbying governance. The company states that the “ESG Initiative Group, as the operational body, deliberates on all matters related to the environment, energy, and greenhouse gases, including engagement activities and the overall climate strategy, to ensure consistency” and that it “continuously monitors and evaluates its external participation activities to ensure alignment with its environmental commitments and global climate goals, including those outlined in the Paris Agreement.” When misalignments are found, “the ESG Initiative Group conducts a thorough review and reports its findings to the CLO, who then determines next steps,” after which the findings are escalated to “the CEO and the ESG Committee for further deliberation.” Oversight responsibility is clearly assigned: “The CLO assesses the impacts… and decides whether to take further action, subsequently reporting these findings to the CEO and the ESG Committee,” while the ESG Committee of the Board “finalizes decisions” on key issues. This chain of monitoring, review, and board sign-off demonstrates both a policy and a concrete mechanism for keeping engagement activities aligned with climate strategy, and it names the specific bodies (ESG Initiative Group, CLO, CEO, ESG Committee) that carry that oversight. However, the disclosures do not provide evidence of a stand-alone lobbying-alignment audit, make no mention of procedures that explicitly differentiate between direct company lobbying and indirect lobbying via trade associations, and give no examples of correcting or exiting associations whose positions conflict with SK Telecom’s climate goals. The process therefore suggests moderate governance, with clear oversight and a stated alignment review, but without the detailed coverage and public reporting that would demonstrate a stronger, more comprehensive climate-lobbying governance system.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Strong	SK Telecom provides a strong level of transparency around its climate-related lobbying. It identifies the key regulations it engages on, notably the Ministry of Science and ICT’s 2050 Digital Carbon Neutrality agenda and proposed amendments to the “Act on the Allocation and Trading of Greenhouse-Gas Emission Permits (KETS),” each described with enough detail to understand the policy context and the company’s role. The company is especially clear about how it lobbies: it describes direct engagement through ad-hoc meetings and “public hearings, round-table dialogues and consultation meetings,” and names its targets, such as the Ministry of Science and ICT and the “Environment and Labor Committee of the National Assembly,” while also explaining its indirect work through the Korea Telecommunications Operators Association and the Corporate Renewable Energy Foundation and even disclosing membership fees for these bodies. SK Telecom also spells out the outcomes it seeks from these efforts, including revisions to the KETS law to adjust free allocation and auction design, enabling power-purchase agreements for telecommunications equipment, securing stable renewable-energy procurement, and, more broadly, achieving company-wide Net Zero by 2050 with interim goals to cut Scope 1+2 emissions 47.7 % and Scope 3 emissions 22.3 % by 2030. By linking these concrete policy positions to its climate targets and explaining both the channels and the decision-makers it approaches, the company demonstrates a high degree of openness about its climate lobbying activities.	3