Nitto Denko Corp – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Nitto Denko provides some insight into how it tries to keep its policy engagement consistent with its climate objectives, noting that "We consider the position statement of trade association when we set a climate change strategy. Our position on climate change issues is consistent with theirs. If their directions are not consistent with us, we will discuss with them to reach an agreement" and confirming a "public commitment … to conduct your engagement activities in line with the goals of the Paris Agreement." This shows that the company at least reviews the climate positions of its industry associations and has a mechanism to seek alignment, indicating governance of indirect lobbying. The broader compliance framework explains that "the compliance department adheres to BCG to guide all compliance decisions, providing business execution departments and Group companies with operational development and support, supervision, and monitoring," but this description is general and does not specifically address lobbying oversight. We found no evidence that the Board or a named executive formally oversees climate-related lobbying, no detailed procedure for monitoring or auditing direct advocacy, and no published review of alignment with trade bodies. Consequently, while an initial process for aligning engagement with climate strategy exists, the disclosure lacks the depth, assigned accountability, and transparency that would demonstrate a more robust lobbying-governance system. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Nitto Denko provides some insight into how it tries to keep its policy engagement consistent with its climate objectives, noting that "We consider the position statement of trade association when we set a climate change strategy. Our position on climate change issues is consistent with theirs. If their directions are not consistent with us, we will discuss with them to reach an agreement" and confirming a "public commitment … to conduct your engagement activities in line with the goals of the Paris Agreement." This shows that the company at least reviews the climate positions of its industry associations and has a mechanism to seek alignment, indicating governance of indirect lobbying. The broader compliance framework explains that "the compliance department adheres to BCG to guide all compliance decisions, providing business execution departments and Group companies with operational development and support, supervision, and monitoring," but this description is general and does not specifically address lobbying oversight. We found no evidence that the Board or a named executive formally oversees climate-related lobbying, no detailed procedure for monitoring or auditing direct advocacy, and no published review of alignment with trade bodies. Consequently, while an initial process for aligning engagement with climate strategy exists, the disclosure lacks the depth, assigned accountability, and transparency that would demonstrate a more robust lobbying-governance system.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Nitto Denko Corp provides only limited insight into its climate-policy lobbying. It indicates that it will “participate in COP29” and use the Japan Pavilion to present its carbon-capture technology, signalling an intention to engage with policymakers on climate issues, but it does not identify any specific law, regulation or formal negotiating agenda it is seeking to influence, so readers cannot see which policy processes are being targeted. The mechanism described is likewise high-level: participation in a global conference is the only channel disclosed and the intended audience is described merely as “policymakers,” with no detail on whether this involves bilateral meetings, written submissions, or work through trade associations. Finally, while the company stresses its commitment to environmental sustainability and the development of “carbon-negative solutions,” it does not spell out the concrete legislative or regulatory outcomes it wants to secure. Overall, the disclosures convey an intention to be part of climate discussions but fall short of providing the specific policies, lobbying methods and desired results that would demonstrate strong transparency.	D