Tokio Marine Holdings Inc

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Tokio Marine Holdings provides an exceptionally detailed picture of its climate-policy lobbying. It names multiple concrete measures it has engaged on, including the "National Biodiversity Strategy and Action Plan 2023-2030," "Japan’s long-term strategy under the Paris Agreement" (approved by Cabinet on 11 June 2019), the "Tokyo Cap-and-Trade Program," promotion of the "adoption of the TCFD Recommendations" in corporate disclosures, and disaster-risk-financing initiatives under the APEC Cebu Action Plan. The company also explains how it seeks to influence these measures, citing direct meetings and submissions to identified decision makers: its Chairman "participated in the Prime Minister’s high-level meeting" on Japan’s Paris strategy; it "discussed with the Ministry of the Environment" the biodiversity strategy; it "engages with Tokyo Metropolitan Government on [the] Tokyo Cap-and-Trade Program"; and it presents policy proposals in fora such as the Asia-Pacific Financial Forum and the APEC Business Advisory Council, targeting finance ministers from nine APEC economies. Finally, Tokio Marine states the concrete outcomes it pursues, such as "proposed CO2 emissions reduction target adjustment procedures" for the Tokyo scheme, encouraging nationwide corporate adoption of TCFD-aligned disclosure, and catalysing catastrophe-bond markets to strengthen regional disaster-risk financing. This combination of clearly named policies, explicit mechanisms and targets, and well-defined desired policy changes demonstrates a very high level of transparency in the company’s climate lobbying disclosure.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Tokio Marine appears to have some oversight structures in place for its lobbying and trade‐association activities related to sustainability but does not provide a clear policy or detailed review process for aligning those activities with its climate commitments. It outlines a “management system for lobbying activities and trade association memberships” and states that “the executive officer who supervises Government and External Relations Department is responsible for lobbying activities in general, Mika Nabeshima, Group Chief Sustainability Officer (CSUO) is also responsible for engaging with lobbying activities or trade associations or maintaining government relations specifically for sustainability‐related issues.” Additionally, “material sustainability‐related issues will be reported to and/or discussed at the Group Sustainability Committee chaired by CSUO,” indicating formal oversight. However, beyond recognizing that “climate change is a global issue that threatens the sustainability of society and is an urgent issue to be addressed,” the company does not disclose a specific policy detailing how lobbying positions are aligned with its climate‐transition plan, nor does it describe a formal process for monitoring or managing those lobbying activities against its climate goals.	2