T&D Holdings Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	T&D Holdings discloses a formal structure that reviews whether its external engagement is consistent with its climate commitments, stating that it has established a “「グループＳＤＧｓ委員会」を、当社の取締役会の傘下に設置” composed of the sustainability/CSR officers of all subsidiaries, and that “各社の取組みはグループＳＤＧｓ委員会および当社の取締役会に報告されています.” This shows both a defined process for monitoring climate-related engagement and clear oversight by a Board-level body, indicating that the company has mechanisms to align its advocacy activities with its climate goals. In addition, it confirms a high-level policy commitment, stating that it has “a public commitment … to conduct [its] engagement activities in line with the goals of the Paris Agreement.” However, the disclosure does not explain how lobbying positions are assessed or corrected, gives no detail on how direct lobbying and indirect lobbying through trade associations are reviewed, and offers no examples of engagement outcomes, so the breadth and depth of the governance framework remain limited. Overall, this indicates moderate governance: key oversight structures and a stated alignment process are present, but the company does not disclose specific monitoring criteria, coverage of industry-association lobbying, or results of any climate-lobbying reviews. View Sources	C

Overall Assessment

Analysis

Score

Moderate

T&D Holdings discloses a formal structure that reviews whether its external engagement is consistent with its climate commitments, stating that it has established a “「グループＳＤＧｓ委員会」を、当社の取締役会の傘下に設置” composed of the sustainability/CSR officers of all subsidiaries, and that “各社の取組みはグループＳＤＧｓ委員会および当社の取締役会に報告されています.” This shows both a defined process for monitoring climate-related engagement and clear oversight by a Board-level body, indicating that the company has mechanisms to align its advocacy activities with its climate goals. In addition, it confirms a high-level policy commitment, stating that it has “a public commitment … to conduct [its] engagement activities in line with the goals of the Paris Agreement.” However, the disclosure does not explain how lobbying positions are assessed or corrected, gives no detail on how direct lobbying and indirect lobbying through trade associations are reviewed, and offers no examples of engagement outcomes, so the breadth and depth of the governance framework remain limited. Overall, this indicates moderate governance: key oversight structures and a stated alignment process are present, but the company does not disclose specific monitoring criteria, coverage of industry-association lobbying, or results of any climate-lobbying reviews.

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Lobbying Transparency

Overall Assessment	Analysis	Score
None	T&D Holdings describes internal climate objectives, such as reducing CO2 emissions and achieving net-zero across its operations, and notes that it conducts “dialogues” with investees and provides financing for decarbonisation projects. However, it gives no indication that these activities are aimed at influencing public policy. The disclosures do not name any specific climate-related laws, regulations or government programmes the company has tried to influence, do not identify any policymakers or public bodies it has approached, and do not explain any legislative or regulatory outcomes it seeks. As a result, there is no transparent evidence of climate-policy lobbying.	E