ANA Holdings Inc

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Comprehensive ANA Holdings provides an unusually granular picture of its climate-policy advocacy. It names multiple concrete measures it works on, including ICAO’s Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA), the EU Emissions Trading System (EU-ETS), the Japanese government’s legally-mandated 2030 Sustainable Aviation Fuel (SAF) supply targets contained in the Clean Energy Strategy, and the CARATS air-traffic modernisation programme, as well as its contribution to the Science Based Targets initiative’s aviation guidance. The company also explains how it seeks to influence those measures, describing direct submissions of opinions to the Ministry of Land, Infrastructure, Transport and Tourism, the Ministry of Economy, Trade and Industry and the Ministry of the Environment, participation in public-private councils and technical sub-committees, collaboration with industry bodies such as IATA, AAPA and the Scheduled Airline Association of Japan, and bilateral assistance to the governments and aviation authorities of Cambodia and Myanmar. It further discloses detailed indirect actions, such as helping the Japan Maritime Association obtain accreditation as a CORSIA verification body and working with the Japan Accreditation Board, clearly identifying each target institution. Finally, ANA states the specific outcomes it is pursuing: “stable procurement of SAF, which is essential for decarbonization,” the “smooth implementation of CORSIA in developing countries,” alignment between EU-ETS and CORSIA, certification of domestic verification bodies under ICAO rules, and establishment of large-scale SAF production capacity so that wholesalers replace 10 % of aviation fuel with SAF by 2030. By setting out the policies, the channels it uses to influence them and the precise changes it wants to see, the company demonstrates a comprehensive level of transparency around its climate-related lobbying activities. 4
Lobbying Governance
Overall Assessment Comment Score
Strong ANA Holdings Inc. has established a clear governance process for its climate lobbying, publicly committing to "conduct engagement activities in line with the goals of the Paris Agreement" and setting up a Group ESG Management Promotion Committee, chaired by the Chief ESG Promotion Officer and led by the President and CEO, which meets "four times a year" to "discuss important policies and measures related to environmental issues, including climate change, and to monitor progress toward targets". The committee reviews all activities with policymakers, including direct engagement by executives in government committees and indirect lobbying through trade bodies such as "the Japan Airlines Association and IATA" and international organizations like "ICAO", verifying that they "are consistent with the medium-term management strategy and other climate change strategies". While this framework provides senior oversight and recurring alignment checks, we found no evidence of a dedicated, public audit or third-party report assessing the alignment of its climate-related lobbying. 3