CTBC Financial Holding Co Ltd – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	CTBC Financial Holding discloses a limited yet structured approach for keeping its policy-related engagement consistent with its climate goals. It states that "CTBC Holding has created the feedback mechanism of a climate transition plan aligning with a 1.5 °C world" and explains that, after receiving climate-related feedback, "related departments… will discuss action plans… [which] then will be reported and reviewed by the ESG Taskforce, or even by the Board," indicating a defined internal pathway and a formal body that reviews climate-related advocacy decisions. The company also says that it has a "public commitment… to conduct your engagement activities in line with the goals of the Paris Agreement" and, when deciding whether to affiliate with outside bodies, "we look into details [of] the counter party’s climate policies… to ensure the engagement will be consistent with our climate commitments," suggesting a screening mechanism for indirect engagement such as membership in initiatives or organisations. However, the disclosure does not describe how direct lobbying by employees is monitored, gives no examples of actions taken to realign or exit misaligned associations, and offers no publicly available audit or report of lobbying activities; therefore the governance appears moderate rather than comprehensive. View Sources	C

Overall Assessment

Analysis

Score

Moderate

CTBC Financial Holding discloses a limited yet structured approach for keeping its policy-related engagement consistent with its climate goals. It states that "CTBC Holding has created the feedback mechanism of a climate transition plan aligning with a 1.5 °C world" and explains that, after receiving climate-related feedback, "related departments… will discuss action plans… [which] then will be reported and reviewed by the ESG Taskforce, or even by the Board," indicating a defined internal pathway and a formal body that reviews climate-related advocacy decisions. The company also says that it has a "public commitment… to conduct your engagement activities in line with the goals of the Paris Agreement" and, when deciding whether to affiliate with outside bodies, "we look into details [of] the counter party’s climate policies… to ensure the engagement will be consistent with our climate commitments," suggesting a screening mechanism for indirect engagement such as membership in initiatives or organisations. However, the disclosure does not describe how direct lobbying by employees is monitored, gives no examples of actions taken to realign or exit misaligned associations, and offers no publicly available audit or report of lobbying activities; therefore the governance appears moderate rather than comprehensive.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Strong	CTBC Financial Holding provides detailed transparency around its climate-related lobbying activities. It clearly identifies multiple specific policies it has engaged with, including the “Green Finance Action Plan 2.0,” the “Legislation for Climate Change Adaptation,” and the “Taiwan Taxonomy Regulation.” The company outlines its lobbying mechanisms and targets, describing visits and discussions with the “Financial Supervisory Commission,” “Central Bank,” “Environmental Protection Administration,” “Office of Energy and Carbon Reduction,” and “Executive Yuan,” and sharing its experience in TCFD and introducing the PCAF calculation methods. CTBC also specifies the outcomes it seeks, notably to “introduce the PCAF methodology when formulating relevant legislation of TCFD Guidance in Taiwan,” revealing clear policy objectives. Overall, the company demonstrates a strong level of transparency in disclosing its climate policy lobbying.	B