Tokyo Electric Power Co Holdings Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Tokyo Electric Power Company Holdings discloses a governance structure that links its climate strategy to its policy-engagement activities, indicating a moderate level of lobbying governance. The company states that “Since we engage with the government about policy based on climate change handling policies determined through this process, our handling of this matter is consistent,” and confirms that it has “a public commitment… to conduct… engagement activities in line with the goals of the Paris Agreement.” Oversight responsibilities are clearly assigned: “The Board of Directors oversees climate change risks and opportunities by reviewing strategies, action plans, achievements and the progress with achieving goals,” while an “ESG Managing Executive… gives quarterly reports to the Board of Directors,” and the “ESG Committee, for which the President serves as Chairman, regularly discusses ESG-related issues.” These disclosures describe a policy and an internal process for keeping governmental engagement aligned with climate objectives and identify specific bodies and individuals who monitor that alignment, which indicates solid governance foundations. However, the company does not disclose how it monitors or manages the climate-policy stances of trade associations, nor does it publish a detailed lobbying-alignment review or describe corrective actions when misalignment is found, so the depth and coverage of the process remain limited. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Tokyo Electric Power Company Holdings discloses a governance structure that links its climate strategy to its policy-engagement activities, indicating a moderate level of lobbying governance. The company states that “Since we engage with the government about policy based on climate change handling policies determined through this process, our handling of this matter is consistent,” and confirms that it has “a public commitment… to conduct… engagement activities in line with the goals of the Paris Agreement.” Oversight responsibilities are clearly assigned: “The Board of Directors oversees climate change risks and opportunities by reviewing strategies, action plans, achievements and the progress with achieving goals,” while an “ESG Managing Executive… gives quarterly reports to the Board of Directors,” and the “ESG Committee, for which the President serves as Chairman, regularly discusses ESG-related issues.” These disclosures describe a policy and an internal process for keeping governmental engagement aligned with climate objectives and identify specific bodies and individuals who monitor that alignment, which indicates solid governance foundations. However, the company does not disclose how it monitors or manages the climate-policy stances of trade associations, nor does it publish a detailed lobbying-alignment review or describe corrective actions when misalignment is found, so the depth and coverage of the process remain limited.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Moderate	TEPCO’s disclosures offer a moderate level of transparency around its climate lobbying. The company identifies a single policy focus—Japan’s carbon pricing and carbon tax—stating, “We collaborate with policy makers on the carbon tax,” but does not name additional specific policies or legislation. It explains how it engages with policymakers, reporting that it is “conveying its opinions to these deliberation councils, and METI and the Ministry for the Environment, both directly and via industry organizations,” yet it provides no further mechanisms such as letters or consultations with other entities. TEPCO also outlines two policy outcomes it seeks: advocating for carbon pricing that does not hinder electrification and proposing a review of the renewable energy fixed-price purchase system, and aims “to contribute to better policy discussions by providing opinions that contribute to low-carbon/decarbonization,” but stops short of detailing multiple distinct, measurable objectives. Overall, the disclosures include some clear examples of engagement methods and desired outcomes, but remain limited in scope and detail.	C