Mitsubishi Heavy Industries Ltd – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Mitsubishi Heavy Industries provides some insight into how it governs climate-related engagement, noting that it has created a "Materiality Council, chaired by the CEO, to establish a system to instruct business divisions to take necessary measures" and that, since October 2021, this body "construct[s] a structure to instruct business divisions" so that "engagement activities are consistent with your overall climate change strategy." The disclosure also states that the company has issued a "carbon neutral declaration" and maintains "a public commitment … to conduct [its] engagement activities in line with the goals of the Paris Agreement," while it "collaborated with industry associations, including participating in initiatives such as Keidanren … ‘Challenge Zero’." This indicates a named senior-level forum that oversees external engagement and a stated intention to align such engagement with its climate goals, which demonstrates some governance beyond mere policy declarations. However, the company does not disclose any systematic process for reviewing or auditing the climate-policy positions of its own lobbying or those of its trade associations, nor does it describe how misalignments would be identified, escalated, or corrected; we found no evidence of a dedicated climate-lobbying audit, public alignment report, or criteria for continuing or exiting associations. Accordingly, the governance appears to cover strategic oversight but lacks detailed monitoring mechanisms and transparency on both direct and indirect lobbying alignment. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Mitsubishi Heavy Industries provides some insight into how it governs climate-related engagement, noting that it has created a "Materiality Council, chaired by the CEO, to establish a system to instruct business divisions to take necessary measures" and that, since October 2021, this body "construct[s] a structure to instruct business divisions" so that "engagement activities are consistent with your overall climate change strategy." The disclosure also states that the company has issued a "carbon neutral declaration" and maintains "a public commitment … to conduct [its] engagement activities in line with the goals of the Paris Agreement," while it "collaborated with industry associations, including participating in initiatives such as Keidanren … ‘Challenge Zero’." This indicates a named senior-level forum that oversees external engagement and a stated intention to align such engagement with its climate goals, which demonstrates some governance beyond mere policy declarations. However, the company does not disclose any systematic process for reviewing or auditing the climate-policy positions of its own lobbying or those of its trade associations, nor does it describe how misalignments would be identified, escalated, or corrected; we found no evidence of a dedicated climate-lobbying audit, public alignment report, or criteria for continuing or exiting associations. Accordingly, the governance appears to cover strategic oversight but lacks detailed monitoring mechanisms and transparency on both direct and indirect lobbying alignment.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Mitsubishi Heavy Industries offers only limited insight into its climate-policy lobbying. It notes that it "provides relevant ministries and agencies with input on technologies and the latest trends" and that it participates in unspecified "councils and investigative bodies," indicating some engagement mechanism but without naming the government departments, legislators or jurisdictions involved. The company references broad policy areas—including carbon pricing systems such as the EU ETS and UK ETS, Indonesia’s low-carbon strategy, and U.S. initiatives like the Inflation Reduction Act and Infrastructure Investment and Jobs Act—but it does not identify any specific bill, regulation or rule it has sought to influence. Likewise, the outcomes it pursues are framed only in general terms, calling for "policy support from government… to act as a catalyst to advance clean technologies at scale" and for "effective carbon trading or pricing schemes," without spelling out concrete amendments, targets or time-bound objectives. As a result, while MHI acknowledges that it interacts with policymakers and has broad preferences for supportive decarbonisation policies, the disclosure stops short of detailing which policies it lobbies, how it does so, or the precise changes it wants to see.	D