HD Hyundai Construction Equipment Co Ltd – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	HD Hyundai Construction Equipment discloses a defined structure for managing and approving its climate-related public policy engagement: Ultimately, the Chief Sustainability Officer (CSO) manages the overall direct and indirect public engagement regarding climate change, and the CSO reports to the ESG Committee under the Board of Directors (BOD), after which the final decision is authorized by the Committee. The company states that since 2021, HCE has been reinforcing its governance by establishing the ESG Committee to make decisions on company-wide ESG strategies and policy directions and regularly monitor the implementation progress, and notes that the Committee is chaired by an outside director and the CEO participates as a committee member, which identifies clear senior-level oversight. It also acknowledges indirect lobbying by explaining that HCE raises its opinions through the Korea Construction Equipment Industry Association regarding policy issues that need to be addressed to the government, indicating that both direct and trade-association channels fall under the CSOs remit. This demonstrates a governance mechanism aimed at aligning engagement activities with its climate strategy and its public commitment to conduct [its] engagement activities in line with the goals of the Paris Agreement. However, the company does not disclose any formal review of trade-association positions, criteria for assessing misalignment, or examples of correcting or exiting associations, nor does it publish a dedicated lobbying-alignment report, so the depth of monitoring and transparency remains limited. View Sources	2

Overall Assessment

Analysis

Score

Moderate

HD Hyundai Construction Equipment discloses a defined structure for managing and approving its climate-related public policy engagement: Ultimately, the Chief Sustainability Officer (CSO) manages the overall direct and indirect public engagement regarding climate change, and the CSO reports to the ESG Committee under the Board of Directors (BOD), after which the final decision is authorized by the Committee. The company states that since 2021, HCE has been reinforcing its governance by establishing the ESG Committee to make decisions on company-wide ESG strategies and policy directions and regularly monitor the implementation progress, and notes that the Committee is chaired by an outside director and the CEO participates as a committee member, which identifies clear senior-level oversight. It also acknowledges indirect lobbying by explaining that HCE raises its opinions through the Korea Construction Equipment Industry Association regarding policy issues that need to be addressed to the government, indicating that both direct and trade-association channels fall under the CSOs remit. This demonstrates a governance mechanism aimed at aligning engagement activities with its climate strategy and its public commitment to conduct [its] engagement activities in line with the goals of the Paris Agreement. However, the company does not disclose any formal review of trade-association positions, criteria for assessing misalignment, or examples of correcting or exiting associations, nor does it publish a dedicated lobbying-alignment report, so the depth of monitoring and transparency remains limited.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Strong	HD Hyundai Construction Equipment has demonstrated a high level of transparency in identifying the specific climate policies it lobbies, naming the “Emission Trading System,” the “Framework Act on Low-carbon Green Growth,” and the “Emissions Target Management System,” as well as domestic exhaust standards such as the Tier-4 Stage V exhaust regulation, and explaining its compliance obligations and risks under these schemes. Its disclosures also clearly outline the channels and targets of its advocacy, noting that it “communicates with officials from government and public organizations through official communication channels such as government-led policy briefings related to emissions regulations and the emission trading scheme (ETS),” engages in “public hearings with regulatory-related national institutions,” and provides manufacturer views in consultations on exhaust and refrigerant regulations. However, while it sets out corporate goals like “efforts to reduce GHG emissions” and “finalizing the GHG emissions and target,” it stops short of specifying the policy changes or legislative amendments it is seeking, focusing instead on adhering to existing regulatory frameworks. This indicates strong transparency around what and how it lobbies, alongside more general statements regarding its desired outcomes.	3