KISWIRE Ltd – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Limited	KISWIRE discloses a high-level process for keeping its external engagement aligned with its climate strategy, stating that "KISWIRE's climate change strategy is being made through the Management Strategy Meeting, which is the top decision-making body in the group" and that "the environment & safety team (internal) and the strategic planning division (external) exchange opinions to maintain consistency of internal and external strategies." The company adds that, should major issues arise, these two units "shall present the relevant information as an agenda for the Management Strategy Meeting and proceed with the revision of the strategy according to environmental changes," and confirms a "public commitment … to conduct your engagement activities in line with the goals of the Paris Agreement." This indicates some oversight and a stated intent to align engagement (which could include lobbying) with climate objectives. However, the disclosure does not specify whether the process explicitly covers direct lobbying or participation in trade associations, provides no detail on how alignment is monitored beyond ad-hoc escalation, and does not name an individual or committee responsible for ongoing lobbying governance, so the transparency and robustness of climate-lobbying oversight remain limited. View Sources	D

Overall Assessment

Analysis

Score

Limited

KISWIRE discloses a high-level process for keeping its external engagement aligned with its climate strategy, stating that "KISWIRE's climate change strategy is being made through the Management Strategy Meeting, which is the top decision-making body in the group" and that "the environment & safety team (internal) and the strategic planning division (external) exchange opinions to maintain consistency of internal and external strategies." The company adds that, should major issues arise, these two units "shall present the relevant information as an agenda for the Management Strategy Meeting and proceed with the revision of the strategy according to environmental changes," and confirms a "public commitment … to conduct your engagement activities in line with the goals of the Paris Agreement." This indicates some oversight and a stated intent to align engagement (which could include lobbying) with climate objectives. However, the disclosure does not specify whether the process explicitly covers direct lobbying or participation in trade associations, provides no detail on how alignment is monitored beyond ad-hoc escalation, and does not name an individual or committee responsible for ongoing lobbying governance, so the transparency and robustness of climate-lobbying oversight remain limited.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
Moderate	Kiswire provides a moderate level of transparency on its climate-related lobbying. It identifies the concrete policies it has focused on, naming both the EU Carbon Border Adjustment Mechanism (CBAM) and the Korean Government’s proposal to introduce a carbon tax, and explains how these interact with the existing Korean Emissions Trading Scheme. The company also specifies how it lobbied and whom it targeted, disclosing that it communicated its position to the Korean Government “through discussions with the Korean Steel Association” and presented its arguments directly to EU authorities. Finally, it makes clear what it wanted to achieve: it “argued that it should be excluded from the CBAM list” on the basis that “greenhouse gas emissions are already efficiently managed through ETS,” and it sought to block a domestic carbon tax because of what it sees as duplicative regulation. While the disclosure covers two key policies, two distinct mechanisms and two clearly articulated outcomes, it does not extend to a wider set of climate policy engagements, so the transparency can be considered moderate overall.	C