InfluenceMap's Submission to the SSBJ’s Climate-related Disclosure Consultation

InfluenceMap's Submission Recommends Inclusion of Corporate Climate Policy Engagement as a Disclosure Requirement

July 2024

InfluenceMap's Submission to the SSBJ’s Proposed Climate-related Disclosure Process and Invitation to Interested Parties to Utilize our Recommendations


InfluenceMap intends to submit the attached comment to the The Sustainability Standard Board of Japan (SSBJ) recommending the inclusion of climate policy engagement in Japan's upcoming climate disclosure framework.

This document is designed as a reference for investors and other interested parties who are submitting comments and recommendations to the SSBJ’s consultation process. It provides a rationale as to why corporate climate policy engagement is a necessary part of any corporate climate disclosure. Interested parties are invited to utilize InfluenceMap's recommendations (contained within the download files to the right) in their own submissions to the SSBJ process.

The Sustainability Standards Board of Japan (SSBJ) is inviting comments on its Exposure Drafts of the Sustainability Disclosure Standards for the Japanese market. The Sustainability Disclosure Standards are drafted according to the IFRS Sustainability Disclosure Standards developed by the International Sustainability Standards Board (ISSB).

The SSBJ guidelines as currently proposed do not explicitly consider the issue of corporate climate policy engagement. InfluenceMap's submission to the SSBJ advocates for the inclusion of this issue, and explains why it is an important and useful addition to the draft requirements.

The deadline for submitting feedback is July 31st, 2024. Investors may find it helpful to consult InfluenceMap's submission, available for download at this page, which lays out key asks and provides recommendations that investors may incorporate into their own submissions.

We also invite interested parties to contact us for further information on our recommendations or related matters. Please contact  reina.hosoi@influencemap.org  and  monica.nagashima@influencemap.org.

Please note that InfluenceMap’s submission will be made in Japanese. The English version is for reference only.


Why Mandatory Disclosure of Climate Policy Engagement Matters:

InfluenceMap's comment (available for download at this page) argues that investors and other stakeholders deem information on corporate engagement with climate policy to be essential to understanding an entity’s enterprise value. Poor climate policy engagement can result in investor loss due to company risk, regulatory fines, and lawsuits. It also serves as a proxy for true management thinking on how a company is approaching the material risks relating to climate change.

Toward this aim, InfluenceMap's submission suggests four key areas in which a company could be required to disclose:

  • The governance body(s) (which can include a board, committee or equivalent body charged with governance) that are responsible for oversight of the company's climate policy engagement activities.
  • The governance processes in place to monitor, manage and oversee climate policy engagement activities. This should include an account of how the company has sought to monitor, review and ensure alignment between (i) the company’s overall climate strategy and its climate policy engagement and (ii) the company’s direct climate policy engagement and its indirect policy engagement conducted by third parties it funds and/or is a member of.
  • Climate policy risks/opportunities that might impact the company’s prospects. This should cover all existing or upcoming government climate-related policy interventions that might impact the company, as well as details on the policy interventions the company requires from governments to deliver on its climate transition plan.
  • Policy engagement activity: A full account of how the company has responded to or plans to respond to climate-related policy risks and opportunities through its policy engagement activities. This should cover all climate advocacy positions held by the company, and what policy engagement activity has been conducted on these positions, both directly by the company and by third parties it funds and/or is a member of, such as industry associations.

    InfluenceMap made similar arguments and asks in our comments to the SEC’s Climate-Related Disclosures proposal, EFRAG’s Sustainability Reporting Standards, Australian Treasury, and ISSB.

    If you would like to discuss further, please do not hesitate to get in touch - see emails at top of page

About InfluenceMap

InfluenceMap is a non-profit think tank providing objective and evidence-based analysis of how companies and financial institutions are impacting the climate and biodiversity crises. Our company profiles and other content are used extensively by a range of actors including investors, the media, NGOs, policymakers, and the corporate sector. InfluenceMap does not advocate or take positions on government policy. All our assessments are made against accepted benchmarks, such as the Intergovernmental Panel on Climate Change. Our content is open source and free to view and use (https://influencemap.org/terms).

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