Nippon Paint Holdings Co Ltd – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Strong	Nippon Paint Holdings discloses a defined oversight structure and iterative review process that covers both direct and indirect policy engagement and is expressly tied to its climate-related strategies, indicating strong governance. The company states that “our major direct and indirect external activities are reported several times a year by the Global Teams to the Co-Presidents and by the Co-Presidents to the Board of Directors, to ensure that they are aligned with Nippon Paint’s policies and strategies related to climate change and water,” revealing a regular, board-level review mechanism. Alignment checks are embedded in day-to-day operations, as “the department in charge of ESG promotion and sustainability checks each time whether the content of external responses is consistent with our environmental policy and strategy… If any inconsistency is found, this process will be repeated again until consistency is ensured,” demonstrating an explicit procedure for monitoring and correcting lobbying positions. Indirect lobbying through trade bodies is also addressed: “through our membership in the Japan Chemical Industry Association, we confirm whether policies align with our strategies,” and all such engagements are “reported to the ESG Committee on a quarterly basis to verify whether they align with our climate change strategy.” Governance responsibilities are clearly assigned, with the “ESG Promotion Department, which is the secretariat for the ESG Committee,” conducting the checks, material matters being “discussed by the ESG Committee and then approved by the Board of Directors.” While the disclosure outlines oversight bodies, frequency of reviews, and an escalation process to resolve misalignment, the company does not publish a detailed climate-lobbying alignment report or describe instances of exiting associations, so transparency on outcomes remains limited. View Sources	B

Overall Assessment

Analysis

Score

Strong

Nippon Paint Holdings discloses a defined oversight structure and iterative review process that covers both direct and indirect policy engagement and is expressly tied to its climate-related strategies, indicating strong governance. The company states that “our major direct and indirect external activities are reported several times a year by the Global Teams to the Co-Presidents and by the Co-Presidents to the Board of Directors, to ensure that they are aligned with Nippon Paint’s policies and strategies related to climate change and water,” revealing a regular, board-level review mechanism. Alignment checks are embedded in day-to-day operations, as “the department in charge of ESG promotion and sustainability checks each time whether the content of external responses is consistent with our environmental policy and strategy… If any inconsistency is found, this process will be repeated again until consistency is ensured,” demonstrating an explicit procedure for monitoring and correcting lobbying positions. Indirect lobbying through trade bodies is also addressed: “through our membership in the Japan Chemical Industry Association, we confirm whether policies align with our strategies,” and all such engagements are “reported to the ESG Committee on a quarterly basis to verify whether they align with our climate change strategy.” Governance responsibilities are clearly assigned, with the “ESG Promotion Department, which is the secretariat for the ESG Committee,” conducting the checks, material matters being “discussed by the ESG Committee and then approved by the Board of Directors.” While the disclosure outlines oversight bodies, frequency of reviews, and an escalation process to resolve misalignment, the company does not publish a detailed climate-lobbying alignment report or describe instances of exiting associations, so transparency on outcomes remains limited.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Nippon Paint Holdings offers only limited insight into its climate-related lobbying. The company indicates that it engages indirectly through membership bodies such as the Japan Chemical Industry Association and by participating in Keidanren’s Commitment to a Low Carbon Society, but it does not describe concrete tools like letters, consultations or meetings, nor does it name any specific government departments or legislators it approaches. Its disclosures refer broadly to supporting “global warming countermeasures,” curbing emissions in domestic operations and spreading low-carbon products, yet no individual laws, regulations or rule-makings are identified. Similarly, the stated objectives remain high-level ambitions—contributing to net-zero targets and carbon-neutral policies—without detailing the precise policy changes or thresholds it seeks to influence. As a result, while the company signals some engagement on climate policy, the absence of identifiable policies, mechanisms and concrete outcomes limits the transparency of its lobbying activities.	D