Shimizu Corp – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Strong	Shimizu Corp has established a governance framework in which “the results of direct and indirect activities where Shimizu may influence public policies are all deliberated in the SDGs and ESG Promotion Committee to ensure consistency with the stance and approach of our business strategy related to climate change.” Once “appropriateness and consistency with our business strategy is confirmed,” outcomes are “disclosed widely by IR and other procedures,” and if “a major deviation from the direction of policy or the activities of The Japan Business Federation (JBF) and The Japan Federation of Construction Companies (JFCC) is identified, we have a process that the Committee deliberates the policy including continuity/revision of our mid-term management plan and reports the result to the Board of Directors.” The framework further ensures that “where the Company’s medium- to long-term business strategy is judged to be consistent with the direction of public policy, the annual strategy is reflected in the short-term business action plan” and embedded within its Environmental Management System PDCA cycle. Shimizu also confirms a “public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement? […] Yes,” underscoring its alignment with global climate objectives. While this demonstrates active oversight of both direct and indirect lobbying by a formal committee and escalation to board level, the company does not disclose any dedicated audit or third-party review on climate-lobbying alignment nor detail the specific methodology for assessing its lobbying activities against its climate commitments. View Sources	B

Overall Assessment

Analysis

Score

Strong

Shimizu Corp has established a governance framework in which “the results of direct and indirect activities where Shimizu may influence public policies are all deliberated in the SDGs and ESG Promotion Committee to ensure consistency with the stance and approach of our business strategy related to climate change.” Once “appropriateness and consistency with our business strategy is confirmed,” outcomes are “disclosed widely by IR and other procedures,” and if “a major deviation from the direction of policy or the activities of The Japan Business Federation (JBF) and The Japan Federation of Construction Companies (JFCC) is identified, we have a process that the Committee deliberates the policy including continuity/revision of our mid-term management plan and reports the result to the Board of Directors.” The framework further ensures that “where the Company’s medium- to long-term business strategy is judged to be consistent with the direction of public policy, the annual strategy is reflected in the short-term business action plan” and embedded within its Environmental Management System PDCA cycle. Shimizu also confirms a “public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement? […] Yes,” underscoring its alignment with global climate objectives. While this demonstrates active oversight of both direct and indirect lobbying by a formal committee and escalation to board level, the company does not disclose any dedicated audit or third-party review on climate-lobbying alignment nor detail the specific methodology for assessing its lobbying activities against its climate commitments.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Shimizu Corp provides only limited transparency on its climate-related lobbying. It indicates that it participates in umbrella initiatives and associations such as the “Japan Federation of Construction Contractors (JFCC),” “Global Compact Network Japan (GCNJ),” the “GX League,” and the “Task Force on Climate-related Financial Disclosures (TCFD) Consortium,” suggesting some level of engagement with climate policy discussions, but it does not name any specific bills, regulations, or rulemakings it has tried to influence. The company likewise offers no description of the mechanisms it uses—there is no reference to letters, meetings, consultations, or the government bodies or lawmakers it approaches. Finally, while it reiterates broad aspirations like achieving “carbon neutrality by 2050” and setting “medium- to long-term reduction targets based on SBT,” these are internal goals rather than clearly defined policy outcomes it is seeking to secure through lobbying. As a result, readers are left with only a general sense that the company is active in climate forums, but virtually no detail about the policies, methods, or specific objectives that shape its external advocacy.	D