Tokyo, 2 October 2023 – On September 29th, Tokio Marine, Japan’s biggest property and casualty insurer and the 7th* biggest globally, announced its “Interim Target for 2030 for the Transition to a Decarbonized Society“. It has set an engagement target within its domestic subsidiary, Tokio Marine & Nichido Fire Insurance Co., Ltd. (TMNF), to engage with 200 major customers, which account for about 90% of greenhouse gas (GHG) emissions in its underwriting portfolio, and achieve level 2 or higher dialogue with more than 160 customers by 2030 (see chart below).

Tokio Marine has become the first Japanese insurer to set an intermediate target, however the commitment is extremely limited. Instead of following its global peers AXA and Allianz, and setting a GHG emissions reduction target in its underwriting portfolio, Tokio Marine has limited its ambition to engagement in a move that lacks impact and scope.

By comparison, AXA has committed to reduce the emissions of its major clients for its underwriting business by 30% by 2030, and Allianz has committed to cut the emissions from its underwriting business by 45% by 2030.

It is unclear how Tokio Marine will ensure its customer’s transition towards a maximum 1.5°C warming target, in line with the Paris Agreement, as it has not published a bold action plan in its engagement target in case of failure to cut GHG emissions. Another major loophole in the engagement target is that it is only limited to its domestic subsidiary, TMNF, and doesn’t include Tokio Marine Kiln, its major international fossil fuel underwriter.

Yuki Tanabe, Campaigner for Japan Center for a Sustainable Environment and Society (JACSES), said: “The effectiveness of Tokio Marine’s targets, based on engagement, is questionable as no meaningful counter measures are included should one of its customers fail to adopt sufficient decarbonisation plans. Tokio Marine should publish a clear 2030 target to reduce their insured GHG emission, as AXA and Allianz have done.”

On May 29th, Tokio Marine left the UN-convened Net Zero Insurance Alliance (NZIA), along with 2 other major Japanese insurers, MS&AD and SOMPO, under pressure from the fossil fuel lobby in the US. On exiting, Tokio Marine announced that it will continue to tackle climate change, however its weak 2030 interim targets raises questions about the company’s commitment.

As one of the world’s largest insurers, Tokio Marine must immediately set an intermediate GHG emissions reduction target and strengthen its engagement target and underwriting policy to exit from fossil fuels.

Peter Bosshard, Global Coordinator of Insure Our Future, said: “Insurance companies like Tokio Marine have engaged fossil fuel companies in a dialogue about the net zero transition for many years, without any tangible impact. The oil and gas industry has expanded its production, and major companies have walked back their net zero commitments. In the face of the climate emergency, Tokio Marine should stop playing games and cease insuring any new fossil fuel projects immediately.”

On 26 June 2023, citizens and environmental NGOs gathered in front of the AGM venue of Tokio Marine Holdings; Japan’s biggest and one of the world’s top 10 oil and gas insurers.

#StopEACOP activists question Tokio Marine’s ethics 

Risa Iizuka, a youth activist and Field Organizer at Japan, condemned the 1,400km-long  East African Crude Oil Pipeline Project (EACOP). This pipeline poses concerns about human rights violations against local residents and environmental destruction in Victoria Lake basin and Tanzania forests.

Yuki Tanabe, a climate campaigner at JACSES, attended the AGM and asked a question whether Tokio Marine is planning to publicly rule out underwriting EACOP. Tokio Marine’s leadership answered, “We cannot comment on an individual project,” even though 23 out of 29 global insurers have announced they are not and will never be involved in this project. A Japanese mega bank; Sumitomo Mitsui Banking Corporation (SMBC) used to remain silent as well; however, the group recently denied its current involvement in the project, as a result of growing movement.

Tokio Marine Holdings’s response on EACOP is not consistent with the group’s past practice. Yuki Tanabe said that, “Tokio Marine previously responded that they didn’t intend to underwrite Adani’s Carmichael coal mine in Australia. Tokio Marine should announce not to underwrite any new fossil fuel projects, including EACOP.”

Tokio Marine’s History of Underwriting Dirty Fossil Fuels

Tokio Marine was also a major underwriter of Brazil’s offshore oil drilling operations, which caused devastating oil spills and conflicts with local residents. In Asia, Tokio Marine was the second largest underwriter of one of the dirtiest coal power plants in Vietnam: Vung Ang 2.

As a result of the growing movement all over the world, we have seen 15 insurers, including Allianz, Swiss Re and Munich Re, commit to restrict their underwriting of oil and gas projects. Tokio Marine updates its climate policy every year; however, its improvements are too minor. To avoid the most dangerous climate catastrophe, we must see Tokio Marine speed up and strengthen its oil and gas policy immediately in line with a credible 1.5C pathway*.

* As outlined in science-based scenarios such as the International Energy Agency (IEA) Net Zero scenario or the One Earth Climate Model (OECM) Decarbonization Pathway.

On 30 September 2022, Tokio Marine, Japan’s biggest international insurer, updated its climate policy to rule out new underwriting and investment in tar sands mining and oil and gas explorations in the Arctic areas. While Insure our Future welcomes the company’s commitment to stop supporting some extreme fossil fuels projects, considering its presence in the global oil and gas market, Tokio Marine must ramp up its oil and gas restrictions to catch up with its 13 global peers including Allianz and Swiss Re, and most recently, Munich Re.

Tokio Marine is one of the world’s top 10 Property and Casualty insurance companies in the oil and gas sector, which underwrite some of the most controversial fossil fuel projects around the world.

A new report reveals that Tokio Marine underwrote one the biggest and dirtiest Liquified Natural Gas (LNG) projects off the coast of Australia: Ichthys LNG. Tokio Marine was also found to be one of the biggest contributors of the offshore oil expansion in Brazil, threatening the livelihood of local communities and the sensitive ecosystem around the Great Amazon Reef. In Asia, Tokio Marine was the second largest underwriter of one of the dirtiest coal power plants in Vietnam: Vung Ang 2.

Tokio Marine’s has also failed to rule out insurance of the East African Crude Oil Pipeline (EACOP), the world’s most controversial pipeline project. If built, EACOP would be the world’s longest heated crude oil pipeline. The pipeline would connect from Uganda to Tanzania, violating the human rights of over 100,000 local residents, and releasing a significant amount of greenhouse gas (GHG) once the project starts operating. Thousands of people from across the world rose up and joined the #MarshDropEACOP campaign to urge the world’s biggest insurance broker, Marsh to stop brokering insurance for the EACOP. Tokio Marine should join its 17 global peers and clearly state that it will never be involved in the world’s worst pipeline project.

NGOs take action at Tokio Marine’s AGM

On 27 June 2022, climate activists gathered in front Tokio Marine’s Annual General Meeting (AGM) venue, urging the company to immediately stop underwriting some of the most controversial fossil fuel projects that drive the climate catastrophe.

2022-06-27 Tokio Marine AGM 2022

According to the NGO members who attended the AGM, although the issue of climate change was highlighted at the meeting, Tokio Marine only mentioned that it is planning to gradually improve its climate policy without committing to a concrete timeline.

Investors engage with Tokio Marine to align with 1.5°C target

In addition to NGOs, investors are also demanding that Tokio Marine align its business activities with the Paris Agreement. Following the AGM, JACSES sent a letter to 50 shareholders of Tokio Marine urging investors to engage with the company to align its business with the Paris Agreement. Some of Tokio Marine’s shareholders, including one of the largest Japanese asset management companies, responded positively to the letter that they will continue to engage with Tokio Marine to set a long-term goal and build a path to achieve net-zero.

Yuki Tanabe, Program Coordinator at JACSES says, “Investors are also concerned that Tokio Marine doesn’t have a concrete policy or plans to achieve the net-zero goal of its insurance portfolio”.

Tokio Marine’s carbon neutrality claim does not take into account its insurance underwriting and investments

In a report released on 13 September 2022, Tokio Marine claims that the Group’s overall business activities in 2021 were “carbon neutral”. The restoration of Mangrove forests would have some positive impacts on the local ecology and some carbon fixation; however, a question remains: how will Tokio Marine take responsibility for the emissions missing from the calculation — emissions from its insurance underwriting and investment portfolio?

Tokio Marine’s fossil fuel policy is far from what is required from a net-zero committed insurer

Tokio Marine is a member of the Net-Zero Insurance Alliance (NZIA), an initiative that aims to achieve net-zero GHG emissions from insurance underwriting portfolios by 2050. The membership automatically also makes it a member of the Glasgow Financial Alliance for Net-Zero (GFANZ) and the UN-backed Race to Zero campaign, which updated its criteria calling all the members to “phase down and out all unabated fossil fuels”. Although the methodology to calculate the amount of emissions from insurance portfolios is under development, Tokio Marine’s global peers in the NZIA including Allianz and Swiss Re are taking action by committing not to insure new oil and gas development projects.

We urge Tokio Marine to catch up with its peers and strengthen its underwriting policy with science-based 1.5°C pathways including the International Energy Agency (IEA) Net Zero scenario and the One Earth Climate Model (OECM) Decarbonization Pathway, which tells us that no new oil and gas projects can be developed in the 1.5°C scenario. As a net-zero committed insurer, Tokio Marine should commit to:

  1. Close loopholes to underwrite new coal power plants and coal mines.
  2. Immediately cease insuring coal companies, unless they have a coal exit plan that commits to close all coal-related assets by 2030 in EU/OECD countries and by 2040 globally.
  3. Immediately cease insuring new oil and gas exploration and production, and start to phase out insurance for oil and gas companies in line with a 1.5°C pathway.
  4. Divest all assets, including assets managed for third parties, from coal, oil and gas companies that are not aligned with a 1.5°C pathway.
  5. Bring stewardship activities, membership of trade associations and public positions as a shareholder and corporate citizen in line with a 1.5°C pathway in a transparent way.
  6. Establish robust due diligence and verification mechanisms to ensure clients fully respect and observe all human rights, including the right to Free, Prior and Informed Consent (FPIC) as articulated in the UN Declaration on the Rights of Indigenous Peoples.

Originally published by Oil Change International on May 27, 2022.

BERLIN – Today G7 climate, energy and environment ministers issued a communique committing to end public finance for fossil fuels by the end of this year. The statement echoes the joint commitment made by 39 countries and institutions at the November 2021 climate negotiations and states that G7 governments will “end new direct public support for the international unabated fossil fuel energy sector by the end of 2022”. The G7 make this commitment to advance national security interests and accelerate the international clean energy transition, which they recognize requires phasing out investment in the unabated fossil fuel sector.

In response, experts at Oil Change International and Friends of the Earth Japan issued the following statement: 

Laurie van der Burg, Public Finance Campaign Co-Manager at Oil Change International said: “The G7 commiting to end public finance for fossil fuels and shift it to clean is a massive win. In the context of Russia’s fossil-fueled war and signs that some of the G7 members who agreed to end their public fossil finance last November may backslide by pursuing new gas investments, this statement is a timely reconfirmation that the most viable pathway to energy security is prioritizing public finance for clean energy. These promises should now urgently be turned into action. Strong implementation is needed — both for the G7 to shift their $33 billion a year in fossil fuel finance and for them to be able to encourage even more countries to join them.”

Susanne Wong, Asia Program Manager at Oil Change International said: “Japan joining this G7 commitment is a significant step forward for people and our planet. Japan is the second largest provider of international public finance for fossil fuels and the only G7 member that did not sign a commitment to end public finance for fossil fuels at the COP26 climate talks last year. If Japan implements this commitment with integrity, it will directly shift $11 billion a year from fossil fuels to clean energy and have a much larger indirect impact given Japan’s influence on other financiers in Asia and around the world. This requires that Japan stop financing the expansion of gas infrastructure across Asia and globally and stop promoting technologies that would extend the lifetime of dirty coal plants. If Japan follows through and truly shifts its fossil finance to clean energy, this will help to speed the just energy transition we so desperately need.”

Ayumi Fukakusa, Climate and energy campaigner from Friends of the Earth Japan “Japan is the second largest provider of public finance to fossil fuels so this is a significant step. However, Japan has a bad track record of implementing its commitments. Last year, the G7 committed to end new direct government support for international coal power projects by the end of 2021, but Japan still intends to support two new coal projects in Indonesia and Bangladesh. Japan must implement its commitments with integrity to shift the actual flow of money. Also, Japan has not committed to a full coal phase-out domestically and is still constructing new coal power plants. Now Japan must accelerate the decarbonization of its electricity sector without relying on destructive energy such as nuclear as well as prioritizing energy saving and energy efficiency.”



Nicole Rodel – nicole [at]
Laurie van der Burg — laurie [at]


  • The $33 billion per year quoted above is from a recent G7 factsheet from Oil Change International, Friends of the Earth U.S., Asian People’s Movement on Debt and Development, Friends of the Earth Japan, and International Institute for Sustainable Development based on data from the open-access Public Finance for Energy Database (, a project tracking financial flows to fossil fuels and clean energy from G20 bilateral development finance institutions (DFIs), export finance agencies (ECAs), and the multilateral development banks (MDBs). From 2018-2020, G7 governments spent over $100 billion on public finance for fossil fuels.
  • The countries and the institutions that previously signed the joint Glasgow statement on public finance in November 2021 include: Agence Française de Développement (AFD), Albania, Canada, Costa Rica, Denmark, Banco de Desenvolvimento de Minas Gerais (BDMG), The East African Development Bank (EADB), El Salvador, Ethiopia, Fiji, Finland, Netherlands Development Finance Company (FMO), France, Germany, Mali, Marshall Islands, New Zealand, Moldova, Portugal, Slovenia, South Sudan, Spain, Sri Lanka, Switzerland, the European Investment Bank, The Gambia, The United Kingdom, the United States and Zambia.
  • Last week, 120+ CSOs released letters to 11 Glasgow Statement signatory countries with specific recommendations for implementation on their fossil free public finance commitments: Canada, Germany, Netherlands, Italy, France, Portugal, United Kingdom, United States, Costa Rica, El Salvador, and New Zealand
  • An April 2022 briefing from Oil Change International on recent trends in international public finance for fossil fuels, and how these financial flows could be used instead to unlock a globally just transition.
  • Oil Change International data on shows that most international public finance for energy has flowed between wealthy countries rather than supporting development in the Global South. Poor contract terms, debt traps, and disproportionate ownership by foreign multinationals have meant fossil finance has usually undermined, not supported development when it does flow to low-income countries.
  • legal opinion by Professor Jorge E Viñuales from the University of Cambridge and Barrister Kate Cook of Matrix Chambers argues that governments and public finance institutions that continue to finance fossil fuel infrastructure are potentially at risk of climate litigation.

On September 30, one of Japan’s major non-life insurance companies, Tokio Marine Holdings announced a policy to tighten its restrictions on underwriting coal-related business. The new policy states that “Tokio Marine Group will not provide new underwriting capacities or financing to coal fired power generation projects or thermal coal mining projects, regardless of whether they are newly constructed or not. However, we may grant exceptions for projects with innovative technologies and approaches, such as CCS/CCUS and mixed combustion, with the aim of achieving the goals of the Paris Agreement, based on careful consideration.” While we see it as a certain progress, we consider that the policy needs to be further strengthened to achieve the 1.5 degrees Celsius goal of the Paris Agreement.

In its new policy, Tokio Marine regards CCS/CCUS and mixed combustion as innovative technologies and approaches to achieve the goals set in the Paris Agreement. However, it remains uncertain whether these technologies will become commercially viable within the timeline consistent with the 1.5 degrees Celsius goal of the Paris Agreement and for mixed combustion whether greenhouse gas (GHG) emissions are sufficiently reduced when looked at the whole cycle including mixed fuel’s production and transportation. Therefore, it is not appropriate to include CCS/CCUS and mixed combustion as innovative technologies and approaches to achieve the goals of the Paris Agreement.

In addition, no commitment has been made to reduce emissions in the underwriting portfolios, which is a critical effort to achieve the 1.5 degrees Celsius target. At the Insurance Development Forum held on June 8, UN Secretary-General Antonio Guterres called on insurance companies to end fossil fuel insurance by stating that “we need net zero commitments to cover your underwriting portfolios, and this should include the underwriting of coal ? and all fossil fuels”. The three major non-life insurance companies including Tokio Marine should immediately set a goal to achieve net-zero emissions by 2050 for their underwriting portfolios. In the meantime, all the three Japanese mega banks have already pledged net zero GHG emissions in their lending and investment portfolios by 2050. It is becoming more obvious that the Japanese non-life insurance sector is lagging behind.

Moreover, the International Energy Agency (IEA) concluded in its report, “Net Zero by 2050, A Roadmap for the Global Energy Sector” published on May 18, that new fossil fuel mining operations cannot be approved by the present year 2021 and the electricity sector should have net-zero emissions globally by 2040. Therefore, in order to achieve net zero emissions by 2050, it is necessary to end underwriting not only for coal mining and coal-fired power generation but all fossil fuel mining, transporting and power generation projects, including oil and gas.

This statement was published by Japan Center for a Sustainable Environment and Society (JACSES), Kiko Network, Friends of the Earth Japan, Japan and Mekong Watch.

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