Nippon Steel Corp

Nippon Steel Corp has established a defined climate lobbying governance process under which "important matters are reported to the Board of Directors as they arise, and major progress is reported on a regular basis," and "opinions received from various stakeholders, including institutional investors, are regularly reported and fed back to the Board of Directors," indicating senior-level oversight of climate policy engagement. The company further commits that "the Company shall disclose annually, climate-related and decarbonisation-related policy positions and lobbying activities globally, including its own direct lobbying and industry association memberships, and review these for alignment with the Company's goals of carbon neutrality by 2050 and explain the actions it will take if these activities are determined to be misaligned," demonstrating a systematic process to monitor and align both its direct and indirect lobbying. However, the company does not disclose a specific individual or committee beyond the Board as responsible for these reviews, and we found no evidence of an independent or third-party audit to verify the annual alignment assessments or clarify the criteria and remedial actions that would follow identified misalignments, leaving some implementation details and enforcement mechanisms unclear.