Kobe Steel Ltd – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Kobe Steel discloses a clear internal procedure for overseeing policy engagement that covers both its own advocacy and its participation in industry bodies, noting that "all members of the Group shall report such activities to the Sustainability Management Committee in advance" and that the committee "shall confirm whether such activities are consistent with the Group Corporate Philosophy and ESG policies." This committee-level check is escalated, as the committee "shall report such activities to the Executive Council and the Board of Directors for oversight in accordance with the importance of such activities," indicating board-level visibility and accountability. The company also states that "if the efforts of industry associations/groups are not in line with the Group Corporate Philosophy or ESG policies, Kobe Steel shall put forward its opinions to industry associations/groups and work to ensure that their initiatives are consistent with its policies," which shows an intent to manage indirect lobbying alignment, although no concrete examples of engagements or withdrawals are provided. Finally, Kobe Steel identifies the chair of the Sustainability Management Committee as responsible for this process and confirms a public commitment that lobbying will be conducted "in line with the goals of the Paris Agreement." While this indicates a structured governance process with named oversight bodies and forward-looking alignment mechanisms, the disclosure does not provide evidence of completed reviews, published alignment assessments, or specific corrective actions, so the robustness of implementation cannot yet be verified. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Kobe Steel discloses a clear internal procedure for overseeing policy engagement that covers both its own advocacy and its participation in industry bodies, noting that "all members of the Group shall report such activities to the Sustainability Management Committee in advance" and that the committee "shall confirm whether such activities are consistent with the Group Corporate Philosophy and ESG policies." This committee-level check is escalated, as the committee "shall report such activities to the Executive Council and the Board of Directors for oversight in accordance with the importance of such activities," indicating board-level visibility and accountability. The company also states that "if the efforts of industry associations/groups are not in line with the Group Corporate Philosophy or ESG policies, Kobe Steel shall put forward its opinions to industry associations/groups and work to ensure that their initiatives are consistent with its policies," which shows an intent to manage indirect lobbying alignment, although no concrete examples of engagements or withdrawals are provided. Finally, Kobe Steel identifies the chair of the Sustainability Management Committee as responsible for this process and confirms a public commitment that lobbying will be conducted "in line with the goals of the Paris Agreement." While this indicates a structured governance process with named oversight bodies and forward-looking alignment mechanisms, the disclosure does not provide evidence of completed reviews, published alignment assessments, or specific corrective actions, so the robustness of implementation cannot yet be verified.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Moderate	Kobe Steel’s disclosures on its climate-related lobbying activities are moderately transparent. It has clearly named the one specific climate policy it engaged with—the “GX (Green Transformation) League Basic Concept” published by Japan’s Ministry of Economy, Trade, and Industry in 2022—but does not indicate whether this is its sole engagement. The company states it “participated in explanatory meetings and opinion solicitation sessions organized for GX League member companies” and “made recommendations to policymakers to improve the framework,” providing insight into its methods and the policymaking body it targeted. However, Kobe Steel offers only a general endorsement of improving the GX League framework without specifying any concrete amendments or targets, leaving its desired policy outcomes broad rather than precise.	C