Hithink RoyalFlush Information Network Co Ltd – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
None	Hithink RoyalFlush Information Network Co Ltd provides no disclosure of any specific mechanisms, oversight structures, or accountability measures for governing its lobbying activities. The evidence focuses on ESG and corporate governance reporting – for instance, it states that “we have developed a comprehensive and effective ESG governance structure” under an “ESG Committee – ESG project team” and that “all Rio Tinto America PAC employee contributions are reviewed for compliance with federal and state law” by a separate governing board – but these processes pertain to ESG issue identification and PAC compliance rather than establishing any lobbying governance framework. The disclosure that “Our Board has also adopted Corporate Governance Principles” covering director independence and responsibilities similarly provides no insight into how the company monitors or aligns its direct or indirect lobbying with corporate policy or climate goals. We found no evidence of any policy to ensure lobbying alignment, no named individual or body overseeing lobbying activities, and no procedures for reviewing trade association positions, indicating a complete absence of a discernible lobbying governance process. View Sources	E

Overall Assessment

Analysis

Score

None

Hithink RoyalFlush Information Network Co Ltd provides no disclosure of any specific mechanisms, oversight structures, or accountability measures for governing its lobbying activities. The evidence focuses on ESG and corporate governance reporting – for instance, it states that “we have developed a comprehensive and effective ESG governance structure” under an “ESG Committee – ESG project team” and that “all Rio Tinto America PAC employee contributions are reviewed for compliance with federal and state law” by a separate governing board – but these processes pertain to ESG issue identification and PAC compliance rather than establishing any lobbying governance framework. The disclosure that “Our Board has also adopted Corporate Governance Principles” covering director independence and responsibilities similarly provides no insight into how the company monitors or aligns its direct or indirect lobbying with corporate policy or climate goals. We found no evidence of any policy to ensure lobbying alignment, no named individual or body overseeing lobbying activities, and no procedures for reviewing trade association positions, indicating a complete absence of a discernible lobbying governance process.

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Lobbying Transparency

Overall Assessment	Analysis	Score
None	No evidence found	E