Taiwan Semiconductor Manufacturing Co Ltd – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Limited	TSMC indicates that its external climate-related engagement is expected to follow the same governance lines that guide the Company’s broader climate strategy, noting that “TSMC’s climate change governance and management framework is under the direct supervision of the Board of Directors; The ESG Steering Committee is responsible for establishing the Company’s mid- to long-term climate change management strategies; The ESG Committee integrates the resource and development of interdepartmental climate actions; [and] the Energy Saving and Carbon Emission Reduction Committee…reports to the Board of Directors through the ESG Committee every quarter.” The company also confirms that it has “a public commitment … to conduct [its] engagement activities in line with the goals of the Paris Agreement.” These statements show that engagement activity – which would include lobbying – is at least nominally overseen by named bodies and is expected to align with high-level climate objectives. However, the disclosures do not describe any dedicated process for reviewing or approving specific lobbying positions, give no detail on how direct or trade-association lobbying is monitored or corrected, and do not identify an individual or committee explicitly charged with ensuring lobbying alignment. We found no evidence of trade-association reviews, escalation mechanisms, withdrawal criteria, or a published lobbying-alignment report. As a result, while TSMC makes a high-level commitment and references board-level oversight, the transparency around concrete lobbying-governance mechanisms remains very limited. View Sources	1

Overall Assessment

Analysis

Score

Limited

TSMC indicates that its external climate-related engagement is expected to follow the same governance lines that guide the Company’s broader climate strategy, noting that “TSMC’s climate change governance and management framework is under the direct supervision of the Board of Directors; The ESG Steering Committee is responsible for establishing the Company’s mid- to long-term climate change management strategies; The ESG Committee integrates the resource and development of interdepartmental climate actions; [and] the Energy Saving and Carbon Emission Reduction Committee…reports to the Board of Directors through the ESG Committee every quarter.” The company also confirms that it has “a public commitment … to conduct [its] engagement activities in line with the goals of the Paris Agreement.” These statements show that engagement activity – which would include lobbying – is at least nominally overseen by named bodies and is expected to align with high-level climate objectives. However, the disclosures do not describe any dedicated process for reviewing or approving specific lobbying positions, give no detail on how direct or trade-association lobbying is monitored or corrected, and do not identify an individual or committee explicitly charged with ensuring lobbying alignment. We found no evidence of trade-association reviews, escalation mechanisms, withdrawal criteria, or a published lobbying-alignment report. As a result, while TSMC makes a high-level commitment and references board-level oversight, the transparency around concrete lobbying-governance mechanisms remains very limited.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Taiwan Semiconductor Manufacturing Co. Ltd. discloses an extensive picture of its climate-related lobbying. It identifies multiple concrete policies it works on, including the “Climate Change Response Act” and its provisions on a “carbon pricing mechanism and ETS,” the “Taiwan Renewable Energy Credit Platform” together with the amended regulations governing renewable energy certificates, and Taipower’s “Demand Response measures” aimed at shifting electricity load. The company also spells out how and where it pursues influence: it meets semi-annually through the Electricity Supply Communication Platform, participates in working groups such as the Energy & Resource Committee of TSIA, conducts “official correspondences and visits,” and represents or joins associations like “TSIA, ASIP, TEEMA and CNFI” when engaging specific agencies such as the “MOEA, Bureau of Energy, Bureau of Standards, Metrology and Inspection, Taipower,” and the Environmental Protection Administration. Finally, it is explicit about the results it seeks, for example to “eliminate the gap between regulation and real practice as well as scheme out details for future wheeling transaction,” to secure “Taiwan’s first renewable energy wheeling milestone,” to design the REC platform, and to maintain grid stability through tariff-based Demand Response schemes, while broadly supporting the Climate Change Response Act with only “minor exceptions.” Together these disclosures demonstrate a high level of transparency around the company’s climate-policy lobbying objectives, methods, and targets.	4