Nomura Holdings Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Limited	Nomura Holdings Inc. provides extensive disclosures on its sustainability governance framework, including the roles of its Sustainability Committee, Board of Directors, and various working groups. The Sustainability Committee, chaired by the Group CEO, oversees sustainability strategies and reports to the Board of Directors and Executive Management Board. It also collaborates with working groups such as the TCFD Working Group and the D&I Working Group to address climate-related risks and opportunities. The company states that it contributes to decarbonization by providing direct input to policymakers and through industry associations, and it has a public commitment to align engagement activities with the goals of the Paris Agreement. However, while these disclosures highlight robust sustainability governance, they do not explicitly describe mechanisms, oversight structures, or processes for governing lobbying activities, particularly climate-related lobbying. For example, there is no evidence of a detailed lobbying governance framework, alignment audits, or specific processes to ensure that lobbying activities are consistent with climate goals. Additionally, while the company mentions ESG transaction screening and escalation processes, these pertain to risk management rather than lobbying governance. Therefore, the company does not disclose a clear governance process for lobbying alignment, either direct or indirect, with its climate strategy. View Sources	D

Overall Assessment

Analysis

Score

Limited

Nomura Holdings Inc. provides extensive disclosures on its sustainability governance framework, including the roles of its Sustainability Committee, Board of Directors, and various working groups. The Sustainability Committee, chaired by the Group CEO, oversees sustainability strategies and reports to the Board of Directors and Executive Management Board. It also collaborates with working groups such as the TCFD Working Group and the D&I Working Group to address climate-related risks and opportunities. The company states that it contributes to decarbonization by providing direct input to policymakers and through industry associations, and it has a public commitment to align engagement activities with the goals of the Paris Agreement. However, while these disclosures highlight robust sustainability governance, they do not explicitly describe mechanisms, oversight structures, or processes for governing lobbying activities, particularly climate-related lobbying. For example, there is no evidence of a detailed lobbying governance framework, alignment audits, or specific processes to ensure that lobbying activities are consistent with climate goals. Additionally, while the company mentions ESG transaction screening and escalation processes, these pertain to risk management rather than lobbying governance. Therefore, the company does not disclose a clear governance process for lobbying alignment, either direct or indirect, with its climate strategy.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Strong	Nomura Holdings provides a solid level of detail on its climate-policy engagement. It names two concrete policy processes in which it has intervened – providing feedback on the “Exposure Draft on International Sustainability Standards Board (ISSB)” and participating in the Japanese “TCFD Consortium” – and also references rule-setting work inside the ICMA Green and Social Bond Principles. The company is open about how it seeks to influence these discussions, describing multiple channels such as “providing comments and feedback to policy-makers on the ISSB draft,” sitting on the ICMA Advisory Council, chairing the GX League Business Working Group, and signing collective investor statements; it also identifies specific targets, including Japan’s Ministry of Economy, Trade and Industry, the Financial Services Agency, the Ministry of the Environment, and ICMA’s Executive Committee. Nomura clarifies the policy changes it wants, for example the creation of “a mechanism for appropriately evaluating companies’ climate-related opportunities” and “developing a system that better reflects actual market conditions” within emerging disclosure standards, and it outlines points it is asking regulators to revise in the ISSB draft. While the company could set out a broader range of concrete legislative objectives, the information supplied demonstrates a strong degree of transparency on the policies engaged, the methods used and the outcomes sought.	B