Fubon Financial Holding Co Ltd

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Fubon Financial Holding Co. Ltd. provides a thorough picture of its climate-policy engagement. It explicitly identifies a range of policies it has worked on, including “Taiwan’s Pathway to Net-Zero Emissions in 2050,” the “Green Finance Action Plan 3.0,” the forthcoming “Climate Change Act” (currently the Greenhouse Gas Reduction and Management Act), and the “Taiwan Sustainability Taxonomy Standards,” demonstrating clear disclosure of the regulations it seeks to influence. The company also explains how it lobbies and whom it addresses. It describes taking part in public hearings, task forces and workshops, for example, it “participated in a Taiwan Stock Exchange public hearing on a ‘Sustainable Development Roadmap,’” deployed investment and financing specialists to meetings on the taxonomy standards, and engaged through platforms such as the Taiwan Institute for Sustainable Energy and the Taiwan Alliance for Net Zero Emission. The policymaking targets are named, including the Financial Supervisory Commission, the Taiwan Stock Exchange, the Banking Bureau and the Taiwan Carbon Solution Exchange, showing transparency on both mechanism and audience. Finally, the disclosures spell out the concrete outcomes sought: the company “helped produce a report with suggestions on climate-related financial disclosures by the life insurance sector,” offered recommendations on embedding the TCFD framework, and worked to refine the taxonomy so it “concretely define[s] sustainable economic activity.” By detailing the specific policies, the channels used, the governmental bodies addressed and the precise regulatory changes it advocates, Fubon Financial exhibits a comprehensive level of transparency around its climate-related lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Fubon Financial Holding has put in place a targeted governance framework for its indirect climate lobbying through external associations and lobbying groups. Its “implementation strategy” states that “each unit will individually evaluate whether or not the cooperating academy/association/society and lobbying group comply with the relevant regulations of this declaration,” and that “evaluation results must be reported to the president for approval.” It further commits that, after partnership, “the Company will also review and supervise the organization annually for conflicts with our sustainability policy or negative impacts on the overall climate environment, and actively engage in discussion and action,” and if a group “does not have a specific improvement plan or action ... the cooperation should be gradually reduced or even the partnership should be canceled.” The company also pledges that any “sustainability development and climate action related to … lobbying group” participation “will be publicly disclosed in the sustainability report for that year.” These elements show defined oversight structures, monitoring procedures and accountability measures for indirect lobbying. However, the company does not disclose how its direct lobbying is governed, no board-level committee or named individual beyond the president is specified for lobbying alignment, and there is no evidence of a comprehensive or independent audit of its climate lobbying practices.	2