Nanya Technology Corp – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Strong	Nanya Technology discloses a structured system for managing and aligning its policy engagement with its climate goals. The company states that it has “an internal climate change related procedure on engagements with policy makers” whereby “any direct and indirect activities that influence public policy has to follow the procedure and ensure the consistency with our climate change related strategy,” indicating a formal process for direct lobbying alignment. Indirect lobbying is addressed through the “Public Affairs Participation Group under the Sustainable Development Steering Center to evaluate and review decisions on participating in public affairs,” which “review[s] whether participating public associations are consistent with the goals pursued by the Paris Agreement every year,” demonstrating a recurring screen of trade-association positions against the company’s climate commitments. Oversight responsibilities are clearly assigned: representatives must secure “approval of the General Manager” before attending important climate-related meetings, and the dedicated Participation Group sits within a governance structure that reports through the Sustainable Development Steering Center. These disclosures show that the company monitors both direct and indirect lobbying, applies an annual Paris-alignment test, and names accountable bodies and a senior individual, which indicates strong governance. However, Nanya does not disclose the outcomes of its association reviews or publish a standalone lobbying alignment report, and board-level involvement in approving or auditing lobbying activities is only implied rather than explicitly described, so transparency could be enhanced. View Sources	B

Overall Assessment

Analysis

Score

Strong

Nanya Technology discloses a structured system for managing and aligning its policy engagement with its climate goals. The company states that it has “an internal climate change related procedure on engagements with policy makers” whereby “any direct and indirect activities that influence public policy has to follow the procedure and ensure the consistency with our climate change related strategy,” indicating a formal process for direct lobbying alignment. Indirect lobbying is addressed through the “Public Affairs Participation Group under the Sustainable Development Steering Center to evaluate and review decisions on participating in public affairs,” which “review[s] whether participating public associations are consistent with the goals pursued by the Paris Agreement every year,” demonstrating a recurring screen of trade-association positions against the company’s climate commitments. Oversight responsibilities are clearly assigned: representatives must secure “approval of the General Manager” before attending important climate-related meetings, and the dedicated Participation Group sits within a governance structure that reports through the Sustainable Development Steering Center. These disclosures show that the company monitors both direct and indirect lobbying, applies an annual Paris-alignment test, and names accountable bodies and a senior individual, which indicates strong governance. However, Nanya does not disclose the outcomes of its association reviews or publish a standalone lobbying alignment report, and board-level involvement in approving or auditing lobbying activities is only implied rather than explicitly described, so transparency could be enhanced.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Nanya Technology Corp provides only limited insight into its climate-related lobbying. It identifies one concrete policy focus – the amendment of the Renewable Energy Development Regulations – and notes involvement in broader renewable-energy trading discussions, but it does not lay out a full list of the climate policies on which it engages. The company describes its participation in an Industrial Green Power Demand Research Conference and a forum on renewable-energy trading mechanisms, indicating that it uses conferences and multi-stakeholder forums as indirect lobbying channels; however, it does not name the government bodies or specific decision-makers it seeks to influence. The disclosure also conveys a broad objective of easing the Formosa Group’s energy-supply constraints by exploring group-level or cross-jurisdiction purchases of green power, yet it stops short of specifying measurable legislative or regulatory outcomes it wishes to secure. Because the company gives only one clearly identified policy, vague lobbying channels without targets, and general, non-quantified goals, its transparency on climate lobbying remains limited.	D