Chang Hwa Commercial Bank Ltd

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Strong Chang Hwa Commercial Bank provides a high level of detail on its climate-policy lobbying. It identifies two external regulatory initiatives it has tried to influence—the Financial Supervisory Commission’s “Reduction target setting and strategy planning guidance for financial institutions” and the “Climate-related Risk Management Practice Manual” for Taiwanese banks—describing the focus of each and the jurisdiction involved. The Bank goes further in explaining how it lobbies: it reports that it “suggest[ed] the Bankers Association to include the GHG reduction target setting guide,” attended working-group meetings of the Bankers Association’s Climate Change Risk Management Task Force, issued “speech/proposal at shareholders’ meeting,” and even used measures such as “temporarily prohibited from investing/financing,” while naming its targets (the Financial Supervisory Commission, the Bankers Association, and specific credit and investment counterparties). The outcomes sought are also spelled out in measurable terms, including securing the inclusion of GHG-reduction guidance in industry rules, “the complete elimination of financing and investment for thermal coal and unconventional oil and gas industries by 2040,” a 50 % reduction in such exposure by 2030, and full green credit for carbon-intensive industries by 2050, alongside unqualified support for stronger climate-risk regulation. Together these disclosures demonstrate strong transparency across lobbying mechanisms, the policies involved, and the concrete policy changes the Bank is pursuing. 3
Lobbying Governance
Overall Assessment Comment Score
Moderate Chang Hwa Commercial Bank has established a policy to govern its indirect lobbying through trade associations by mandating that "each related business management unit of associations should evaluate and monitor the association’s climate position before joining and after joining to ensure alignment with the Bank’s position," and requiring that units "inventory and confirm that the climate position of the associations the Bank has joined aligns with our own," with a formal assessment triggered when there are significant discrepancies. This indicates clear oversight of indirect lobbying alignment with its climate goals. However, the company does not disclose any process for governing its direct lobbying activities, nor does it identify a specific individual or formal body charged with reviewing or aligning its lobbying with its climate change strategy. We found no evidence of board sign-off, policy review, or designated oversight for direct lobbying, suggesting that key elements of comprehensive climate lobbying governance are absent from its disclosures. 2