First Financial Holding Co Ltd

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Strong First Financial Holding provides a detailed picture of its climate-policy engagement. It names three distinct policy initiatives it has worked on – the Financial Supervisory Commission’s “Green Finance 2.0” policy, the “Reference Guidelines for the Identification of Sustainable Economic Activities,” and the “Financial Industry Financial Carbon Emission Calculation Guidelines” – enabling readers to identify the exact regulations under discussion. The company also discloses how and where it lobbies: it will “actively participate in related important meetings” with the Financial Supervisory Commission, and it has “participat[ed] as a member of the guidance research group and provid[ed] suggestions during the formulation” of the two technical guidelines, directly targeting the FSC and other relevant Taiwanese ministries. Finally, it is explicit about the results it is seeking, including “clarifying the definition and scope of forward-looking economic activities,” encouraging financial institutions to sign the Equator Principles, relaxing rules to expand green-energy financing, and helping develop Taiwan’s green-bond market. Together these disclosures give a strong, though not exhaustive, account of the company’s policy focus, methods of influence, and desired outcomes. 3
Lobbying Governance
Overall Assessment Comment Score
Moderate First Financial Holding Co. Ltd. demonstrates a moderate governance process for climate-related lobbying by establishing “a management system with regard to climate-related lobbying activities and participation in trade associations” across the Company and its subsidiaries, and by instituting “annual reviews and a monitoring system” to ensure that its direct lobbying and its involvement in “domestic and foreign climate-related trade associations” remain “consistent with the ‘Paris Agreement’.” The company further affirms this alignment by publicly answering “Yes” to having a commitment to conduct engagement activities in line with the goals of the Paris Agreement. However, the company does not disclose a specific individual or formal body responsible for overseeing its climate lobbying activities, indicating that while procedural mechanisms are in place, clear accountability for their execution is not specified. 2