Taiwan Mobile Co Ltd

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Strong	Taiwan Mobile is notably transparent about its climate-related lobbying. It names two concrete policies it has tried to influence: the Memorandum of Cooperation in Waste Mobile Communication Product Recycling Program promoted by the Taiwan Environmental Protection Administration and the Telecommunications Management Act overseen by the National Communications Commission. For both initiatives the company describes in detail how it lobbied, signing multi-year cooperation memoranda with the EPA, attending EPA seminars and submitting proposed incentive schemes, repeatedly meeting with the NCC, and even ‘seeking legislators to assist the proposal’ during the parliamentary review of the Telecommunications Management Act. The intended outcomes of these efforts are also spelled out: raising the mobile-phone recycling rate through trade-in and one-stop disposal services, revising distributor obligations, and ensuring the Act allows base-station and spectrum sharing as well as domestic roaming so that networks can “save up to 74 million kWh of electricity” and cut more than 37,000 tCO₂ each year, with longer-term savings projected to double. By clearly identifying the specific policies, the authorities it targets, the concrete lobbying channels it uses, and the measurable environmental benefits it is pursuing, the company provides a strong level of disclosure on its climate lobbying activities.	3

Lobbying Governance

Overall Assessment	Comment	Score
Limited	Taiwan Mobile has made a public commitment to align its engagement activities with climate goals, stating that it is “aligned with the global climate agreement, the Paris Agreement” and pledges to “control global warming within 1.5 degrees Celsius” and to “actively participate in relevant public/associations and advocacy organizations.” It “actively participates in international sustainability organizations such as the Global e-Sustainability Initiative (GeSI), RE100, the European Chamber of Commerce Taiwan (ECCT), the Low Carbon Initiative (LCI), and the Science Based Targets initiative (SBTi)” and engages in “direct dialogue with policymakers” as well as annual forums such as its Circular Economy Forum to discuss climate solutions. However, the company does not disclose any internal processes or oversight structures for managing or reviewing its lobbying activities, nor does it name an individual or formal committee responsible for ensuring that direct or indirect advocacy is aligned with its climate commitments, and there is no evidence of a defined review or monitoring mechanism for its policy engagement activities.	1