Cosmo Energy Holdings Co Ltd – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Cosmo Energy has established high-level sustainability bodies, with the Sustainability Strategy Committee and Sustainability Committee established “under the supervision of the Board of Directors” to determine and implement policies on corporate ethics and the environment, and it maintains a conflict-resolution mechanism for its indirect lobbying, stating that “If our industry organization were to adopt a position that is significantly weaker or inconsistent with the Cosmo Energy Group Code of Conduct, we would engage with the organization. If the organization failed to revise its position, our Code of Conduct would take precedence.” The company also affirms its intent to align its external engagement with climate objectives by answering “Yes” to having a “public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement.” However, the company does not disclose any structured process for monitoring or managing its direct lobbying efforts, nor does it identify a specific individual or formal oversight body responsible for reviewing lobbying alignment with its climate goals, and we found no evidence of board sign-off on a climate-advocacy plan or periodic auditing of its lobbying activities. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Cosmo Energy has established high-level sustainability bodies, with the Sustainability Strategy Committee and Sustainability Committee established “under the supervision of the Board of Directors” to determine and implement policies on corporate ethics and the environment, and it maintains a conflict-resolution mechanism for its indirect lobbying, stating that “If our industry organization were to adopt a position that is significantly weaker or inconsistent with the Cosmo Energy Group Code of Conduct, we would engage with the organization. If the organization failed to revise its position, our Code of Conduct would take precedence.” The company also affirms its intent to align its external engagement with climate objectives by answering “Yes” to having a “public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement.” However, the company does not disclose any structured process for monitoring or managing its direct lobbying efforts, nor does it identify a specific individual or formal oversight body responsible for reviewing lobbying alignment with its climate goals, and we found no evidence of board sign-off on a climate-advocacy plan or periodic auditing of its lobbying activities.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Cosmo Energy provides a basic level of transparency by identifying the specific policy framework it supports—the GX League Basic Concept, a Japanese initiative designed to deliver 2050 carbon-neutrality and meet the country’s 2030 greenhouse-gas reduction target. It also states the broad outcomes it backs, namely achievement of those national targets and alignment with the Paris Agreement, indicating the direction of change it wants to see. However, the company does not explain how it has tried to influence that policy: it gives no detail on whether it writes letters, meets officials, joins consultations, or works through trade associations, nor does it name the government bodies or individual decision-makers it addresses. Because the lobbying channels and targets remain unspecified, the disclosure offers only limited insight into the company’s actual lobbying activity.	D