Chunghwa Telecom Co Ltd – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Strong	Chunghwa Telecom discloses a clearly structured process to govern how its policy advocacy and trade-association memberships are kept consistent with its climate objectives, indicating strong oversight but not yet providing the depth of a published independent alignment audit. The company states that it has developed "Guidelines in Participation in the Climate and Sustainable Development Public Policies" and put in place "rigorous participation and management mechanisms through pre-participation review and ongoing monitoring" so that any external climate engagement "continues to align with the Paris Agreement". Responsibility for this governance sits at Board level: "The Sustainable Development and Strategy Committee, overseeing the Company’s sustainability efforts, consists of 5-9 directors, predominantly independent, and functions under the Board", while the operational review is handled by "the Sustainable Development Promotion Committee, chaired by the Chief Sustainability Officer, [which] is responsible for… supervising the Company’s engagement in climate and sustainable development-related public policies, participation in associations, and negotiation activities." The company describes explicit escalation steps when misalignment is found: if an association does not adjust its stance after six months, "the Company will terminate any form of support and participation in the association and announce the withdrawal publicly." These disclosures show a policy, a monitoring procedure, and a named governance body covering both direct policy engagement and indirect lobbying via associations, suggesting strong governance. However, we found no evidence of a standalone or third-party climate-lobbying alignment report, nor of public disclosure of the outcomes of the reviews or any actual exits from misaligned bodies, so transparency about implementation remains limited. View Sources	B

Overall Assessment

Analysis

Score

Strong

Chunghwa Telecom discloses a clearly structured process to govern how its policy advocacy and trade-association memberships are kept consistent with its climate objectives, indicating strong oversight but not yet providing the depth of a published independent alignment audit. The company states that it has developed "Guidelines in Participation in the Climate and Sustainable Development Public Policies" and put in place "rigorous participation and management mechanisms through pre-participation review and ongoing monitoring" so that any external climate engagement "continues to align with the Paris Agreement". Responsibility for this governance sits at Board level: "The Sustainable Development and Strategy Committee, overseeing the Company’s sustainability efforts, consists of 5-9 directors, predominantly independent, and functions under the Board", while the operational review is handled by "the Sustainable Development Promotion Committee, chaired by the Chief Sustainability Officer, [which] is responsible for… supervising the Company’s engagement in climate and sustainable development-related public policies, participation in associations, and negotiation activities." The company describes explicit escalation steps when misalignment is found: if an association does not adjust its stance after six months, "the Company will terminate any form of support and participation in the association and announce the withdrawal publicly." These disclosures show a policy, a monitoring procedure, and a named governance body covering both direct policy engagement and indirect lobbying via associations, suggesting strong governance. However, we found no evidence of a standalone or third-party climate-lobbying alignment report, nor of public disclosure of the outcomes of the reviews or any actual exits from misaligned bodies, so transparency about implementation remains limited.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Chunghwa Telecom is fully transparent about its stance on climate-related lobbying. It names the principal climate laws that affect its business—the “Climate Change Response Act,” which embeds Taiwan’s 2050 net-zero goal and carbon fee, and the “Renewable Energy Development Act”—but then clearly states that it takes no steps to influence them. The company explains that its internal rules prohibit political donations or any form of facilitation fee, stating: “According to Article 8 and Article 9 of the ‘Procedures for Ethical Management and Guidelines for Conduct for Chunghwa Telecom Co., Ltd.,’ the company is prohibited from making political donations and from providing or promising any facilitation fees. Therefore, we have not engaged in any lobbying activities related to climate change issues.” By providing this explicit rationale, the company gives complete visibility into the absence of lobbying mechanisms or targets. It also confirms that, because no lobbying is undertaken, it seeks no specific policy outcomes beyond compliance with the existing legislation it has cited. This level of disclosure offers a comprehensive picture of the company’s non-engagement in climate-policy lobbying.	A