FUJIFILM Holdings Corp

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	FUJIFILM Holdings provides an unusually detailed picture of its climate-related lobbying. It names multiple specific measures it has worked on, including the introduction of Japan’s “power wheeling system,” participation in the “Keidanren Carbon Neutral Action Plan,” and compliance with the “Energy Conservation Law in Japan,” as well as engagement in the Ministry of the Environment’s campaign “Growing Momentum for Carbon Neutrality among Companies.” The company also spells out how it seeks to influence policy: it “regularly engage[s] with the Ministry of Economy, Trade and Industry of Japan, and the Ministry of the Environment of Japan on energy efficiency policy,” cooperates in annual government surveys, sends its CEO to make public presentations, and joins collective dialogues such as Japan Climate Initiative sessions with the Minister of the Environment. Finally, it is explicit about the outcomes it pursues, having championed the power-wheeling reform “effective in cutting peak electric power use,” urged the government to raise the 2030 renewable-energy share to 40–50 percent, and backed higher national emissions-reduction targets, describing its stance as “Support with no exceptions.” Taken together, these disclosures demonstrate a comprehensive level of transparency on the policies addressed, the channels used, and the concrete changes FUJIFILM seeks in climate legislation.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	FUJIFILM Holdings Corp maintains an ESG Committee chaired by its president that “deliberates and makes decisions regarding matters related to our climate change activities” and regularly reports “its agenda … to the Board of Directors,” which provides “instructions and guidance” to ensure the effectiveness of the process. This Committee “makes decisions regarding our participation in climate change-related initiatives,” such as endorsing the TCFD recommendations, joining RE100, obtaining SBT validation and approving the introduction of internal carbon pricing. The company describes how it ensures that its indirect policy engagement is consistent with its overall strategy by aligning its support for the Japan Climate Initiative, noting “Since JCI’s direction is in line with our strategy, we continue to support it,” having “participated in an opinion exchange meeting with the Minister of the Environment” and having “announced a message requesting that the renewable energy power target for 2030 be 40-50%.” However, we found no evidence of a dedicated review process or clear criteria for assessing its participation in associations, no explicit coverage of direct lobbying channels, and no detailed sign-off procedures specific to lobbying activities, indicating a lack of a formal climate lobbying governance framework.	2