Sompo Holdings Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Sompo Holdings has implemented a structured governance process to align both its direct and indirect engagement activities with its climate strategy, embedding Sompo Climate Action in its Mid-Term Management Plan and positioning it as a priority issue under a framework of adaptation, mitigation, and social transformation. The company explains that the Sompo group has a process to ensure that direct and indirect activities are consistent with climate change measures, with oversight provided by a Global Executive Committee (4 times a year), which is composed of the CEO of Sompo group and the presidents of group companies alongside a Sustainable Management Committee chaired by CSO, who is responsible for corporate planning and sustainability, through which it confirm[s], report[s], and discuss[es] the alignment with Sompo group strategy. Sompo further demonstrates indirect lobbying governance by participating in economic organizations such as the Japan Business Federation (Keidanren) and the Japanese Association of Corporate Executives and is promoting activities consistent with the goals of the Paris Agreement, and it publicly commits to conduct your engagement activities in line with the goals of the Paris Agreement. Despite strong senior oversight and routine committee reviews, the company does not disclose detailed procedures for reviewing or amending individual lobbying positionssuch as a formal climate-lobbying review process or criteria for exiting associations whose stances diverge from its Paris-aligned objectivesand we found no evidence of specific sign-off or monitoring protocols for discrete direct lobbying initiatives. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Sompo Holdings has implemented a structured governance process to align both its direct and indirect engagement activities with its climate strategy, embedding Sompo Climate Action in its Mid-Term Management Plan and positioning it as a priority issue under a framework of adaptation, mitigation, and social transformation. The company explains that the Sompo group has a process to ensure that direct and indirect activities are consistent with climate change measures, with oversight provided by a Global Executive Committee (4 times a year), which is composed of the CEO of Sompo group and the presidents of group companies alongside a Sustainable Management Committee chaired by CSO, who is responsible for corporate planning and sustainability, through which it confirm[s], report[s], and discuss[es] the alignment with Sompo group strategy. Sompo further demonstrates indirect lobbying governance by participating in economic organizations such as the Japan Business Federation (Keidanren) and the Japanese Association of Corporate Executives and is promoting activities consistent with the goals of the Paris Agreement, and it publicly commits to conduct your engagement activities in line with the goals of the Paris Agreement. Despite strong senior oversight and routine committee reviews, the company does not disclose detailed procedures for reviewing or amending individual lobbying positionssuch as a formal climate-lobbying review process or criteria for exiting associations whose stances diverge from its Paris-aligned objectivesand we found no evidence of specific sign-off or monitoring protocols for discrete direct lobbying initiatives.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Sompo Holdings provides only limited insight into its climate-related lobbying. The company indicates that it will "proactively participate in rule-making and policy proposals" and that it is "strengthening our engagement with the top 20 high greenhouse gas (GHG) emitting investee companies," showing that some form of engagement exists, but it does not reveal the concrete tools it uses—such as meetings, letters or consultation responses—nor does it identify which governmental or regulatory bodies it approaches. Likewise, it refers broadly to promoting "policies related to renewable energy and energy conservation" yet does not name any specific bills, regulations or jurisdictions, leaving readers unable to tell what measures it is actually trying to influence. Finally, while it declares high-level ambitions such as achieving "Net Zero Group GHG Emissions by 2050" and securing "70 % renewable energy by 2030," these are corporate targets rather than clearly defined legislative or regulatory outcomes it seeks through lobbying activity. Because the disclosures remain high-level and omit the concrete policy names, lobbying channels, targets and desired policy changes, the company’s transparency on climate lobbying is limited.	D