Rakuten Group Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Strong	Rakuten discloses a clear governance structure that actively supervises both its direct and indirect climate-related lobbying, indicating strong oversight and alignment mechanisms. The company states that "the Public Policy Office (PPO) … supervises all activities related to policy influence, including those related to climate change, to ensure that the Group strategy goes in line with the policy influence activities," showing an internal process that governs direct engagement with policymakers. For indirect engagement, it explains that "The Environmental Management Promotion Department regularly reviews and monitors Rakuten’s participation in these partnerships and initiatives to ensure that they are consistent with our environmental policy/initiatives and the Paris Agreement" and that, "In case of misalignment, we will further investigate to consider whether we should remain in or withdraw from the organization," demonstrating an explicit review procedure and corrective action. Named functions such as the "manager of Environmental Department’s Climate Change Solution Office" who is "an active member of JANE’s Carbon Neutral Working Group, ensuring that the Group’s external engagement activities are consistent with our climate commitments," further clarify individual accountability for alignment. While these disclosures outline oversight bodies, regular monitoring, and potential withdrawal from misaligned associations, the company does not disclose a standalone public climate-lobbying alignment report or third-party audit, nor does it specify board-level sign-off, so transparency is strong but not comprehensive. View Sources	B

Overall Assessment

Analysis

Score

Strong

Rakuten discloses a clear governance structure that actively supervises both its direct and indirect climate-related lobbying, indicating strong oversight and alignment mechanisms. The company states that "the Public Policy Office (PPO) … supervises all activities related to policy influence, including those related to climate change, to ensure that the Group strategy goes in line with the policy influence activities," showing an internal process that governs direct engagement with policymakers. For indirect engagement, it explains that "The Environmental Management Promotion Department regularly reviews and monitors Rakuten’s participation in these partnerships and initiatives to ensure that they are consistent with our environmental policy/initiatives and the Paris Agreement" and that, "In case of misalignment, we will further investigate to consider whether we should remain in or withdraw from the organization," demonstrating an explicit review procedure and corrective action. Named functions such as the "manager of Environmental Department’s Climate Change Solution Office" who is "an active member of JANE’s Carbon Neutral Working Group, ensuring that the Group’s external engagement activities are consistent with our climate commitments," further clarify individual accountability for alignment. While these disclosures outline oversight bodies, regular monitoring, and potential withdrawal from misaligned associations, the company does not disclose a standalone public climate-lobbying alignment report or third-party audit, nor does it specify board-level sign-off, so transparency is strong but not comprehensive.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Moderate	Rakuten Group offers a moderate level of insight into its climate-policy engagement. It names two specific government programmes it has influenced: the Ministry of the Environment’s “Green Life Point Project,” noting that “Rakuten's proposal to support the campaign was adopted by the Ministry of the Environment in June 2022,” and the inter-ministerial “COOL CHOICE” campaign that encourages actions such as avoiding re-deliveries. These references identify the public bodies involved—the Ministry of the Environment, the Ministry of Economy, Trade and Industry, and the Ministry of Land, Infrastructure, Transport and Tourism—demonstrating that the company is willing to reveal some of its policymaking targets. Rakuten explains that most engagement is indirect, undertaken through the Japan Association of New Economy’s Carbon Neutral Working Group where it “makes policy proposals and holds study sessions,” but it rarely specifies concrete tools such as letters or meetings, so the mechanisms remain only partly transparent. On desired outcomes, the company discloses clear goals: supporting implementation of the Green Life Point incentive scheme and driving further reductions in CO₂ from missed parcel deliveries under COOL CHOICE; beyond these, it limits itself to broad aspirations for renewable energy and carbon neutrality. Together, these disclosures provide identifiable examples of policies, targets and objectives, yet leave gaps in the description of lobbying methods and the full range of legislative issues addressed.	C