Chang Hwa Commercial Bank Ltd

Chang Hwa Commercial Bank has established a policy to govern its indirect lobbying through trade associations by mandating that "each related business management unit of associations should evaluate and monitor the association's climate position before joining and after joining to ensure alignment with the Bank's position," and requiring that units "inventory and confirm that the climate position of the associations the Bank has joined aligns with our own," with a formal assessment triggered when there are significant discrepancies. This indicates clear oversight of indirect lobbying alignment with its climate goals. However, the company does not disclose any process for governing its direct lobbying activities, nor does it identify a specific individual or formal body charged with reviewing or aligning its lobbying with its climate change strategy. We found no evidence of board sign-off, policy review, or designated oversight for direct lobbying, suggesting that key elements of comprehensive climate lobbying governance are absent from its disclosures.