Human Rights
Human Rights and Environmental Due Diligence
Management Policy
- In response to the Corporate Sustainability Due Diligence Directive (CSDDD) passed by the EU on April 24, 2024, TCC Group Holdings proactively reviews and responds to the impacts on the value chain, incorporating the voices of stakeholders such as customers and community residents into decision-making considerations, and actively communicates and responds appropriately.
- The due diligence approach of TCC Group Holdings primarily references the UN Guiding Principles on Business and Human Rights and the Human Rights Due Diligence Training Facilitation Guide; the EU Corporate Sustainability Due Diligence Directive, the Corporate Sustainability Reporting Directive and the European Sustainability Reporting Standards; and the OECD Due Diligence Guidance for Responsible Business Conduct and the Guidelines for Multinational Enterprises.
- TCC Group Holdings reviews its overall human rights and environmental risks at least every three years. The first human rights and environmental due diligence was conducted in 2024; the scope was expanded to further business entities in 2025; and the scope of the 2026 due diligence is aligned with the boundary of the consolidated financial statements.
- For risk identification details, see the TCC Group Holdings 2025 Human Rights and Environmental Due Diligence Risk Identification Statement.
Human Rights and Environmental Due Diligence Process

1. Identify Issue
- Collect various human rights and environmental issues that may affect different rightsholders.
- Reference guidelines and conventions from the United Nations, the EU, the OECD, and the International Labour Organization to compile relevant issues.

2. Assess Risk
- Consult rightsholders to assess risks to human rights and environmental matters, prioritizing the most significant risks based on their severity and likelihood.
- The rightsholders consulted in this due diligence include employees, surrounding community residents, indigenous peoples, migrant workers, and customers.

3. Prevention and Mitigation
- Cease adverse impacts and prevent potential adverse impacts. If adverse impacts persist despite prevention measures, further mitigation is required.

4. Regular Track
- Periodically evaluate the effectiveness of measures to prevent or mitigate adverse impacts.

5. Communication and Disclosure
- Communicate with rightsholders and disclose all relevant information.

6. Remediation Mechanism
- Provide remedial measures for any adverse impacts that have occurred.
- Establish a company grievance mechanism.
Due Diligence Risk Identification and Assessment Steps
| Step | Description |
|---|---|
| Step 1 |
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| Step 2 |
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| Step 3 |
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Rightsholder Consultation Methods and Risk Identification Results
| Rightsholder and Identification Method | Implementation Method | Key Issue Identification Results |
|---|---|---|
Employees
| Risk identification for employees is conducted in two stages, described as follows: Step 1: International Indicators The following international indicators are used to review the risks of human rights issues in the regions where all business entities operate worldwide. The issues corresponding to each indicator are set out in the Appendix of the Risk Identification Statement.
| Step 1: International Indicators
|
Step 2: Questionnaire Potential risks were identified jointly with employees by questionnaire, with gender factors taken into account throughout the risk identification process.
| Step 2: All Employees
Step 2: Female Employees
| |
Migrant Workers
| Scope of business entities covered by the survey: Migrant workers of E-One Moli Corporation (Molicel) and Molie Quantum Energy Corporation under the Battery Energy Business.
| All Migrant Workers
Female Migrant Workers
|
Communities
| Risk identification for communities is conducted in two stages: Step 1 uses international indicators to make a preliminary screening of issues according to industry characteristics, and Step 2 identifies potential risks through a questionnaire to local residents. Where the same issue appears in both steps, this indicates that the international indicators and residents' subjective assessments are consistent. The steps are described as follows: Step 1: International Indicators The ENCORE international indicator is used to make a preliminary screening of the environmental issue risks of the industries to which the Group belongs. The issues corresponding to the indicator are set out in the Appendix of the Risk Identification Statement. This community risk identification covers all business entities worldwide, with each entity mapped to the corresponding ENCORE sector rating according to its operating type (mining sites, cement plants and RMC plants, power plants, port areas, shipping, environmental technology, offices, and so on). Because the operating model of the Charging and Storage Business has no corresponding ENCORE sector category, other international environmental indicators will be used to assess the related risks in future. | Step 1: International Indicators
|
Step 2: Questionnaire Potential risks were identified jointly with local community residents by questionnaire, with gender factors taken into account throughout the risk identification process.
| Step 2: All Community Residents
Step 2: Female Community Residents (identification results identical to those for all residents)
| |
Indigenous Peoples
|
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Customers
|
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| Supplier Survey | Existing suppliers: Risk identification is conducted in two stages, described as follows: Step 1: International Indicators The following international human rights and environmental indicators are used to make a preliminary screening of the human rights and environmental risks of the regions and industries in which the supply chains of all business entities worldwide are located. The regions of the supply chain are defined as the countries in which each business entity operates. The issues corresponding to each indicator are set out in the Appendix of the Risk Identification Statement.
| Step 1: International Indicators Human rights:
Environment:
|
Step 2: Evaluation and Audit
| Step 2 Human rights:
Environment:
| |
New suppliers: A risk assessment is conducted, a sustainability questionnaire (simplified version) is completed, the Supplier Code of Conduct is signed, and the due diligence checklist review is completed, with qualification determined according to the results.
| - |
Prevention, Mitigation and Remediation of Key Human Rights and Environmental Issues
- After assessing the risks of human rights and environmental issues through the aforementioned steps, preventive and mitigating measures are proposed for key human rights and environmental issues based on subsequent steps of the human rights and environmental due diligence process. Additionally, remedial measures are provided for existing impacts. Grievances raised by rightsholders are also an important channel for assessing the effectiveness of management measures; TCC's overall grievance and remediation management measures are summarized in the table below.
- Prevention, mitigation, and remediation measures for key issues are set out in the table below. For detailed information, please refer to the 2025 TCC Group Holdings Sustainability Report.
- Subsequent human rights and environmental due diligence reports will focus on the following key points:
- Track the effectiveness of TCC's prevention, mitigation, and remediation measures for significant human rights and environmental issues.
- Continue to refer to conventions and guidelines from the United Nations, ILO, and OECD, and integrate ISO risk assessment methodologies and management standards to establish a global human rights and environmental risk management mechanism applicable to TCC's global business operations.
- Identify and address systemic human rights and environmental risks, such as climate change risk and the risks associated with an aging population, in the light of the future model scenarios set out in significant domestic and international research reports.
| Item | Management Measures |
|---|---|
| Grievance | Reporting of Misconduct
Employee Grievances
Suppliers
Migrant Workers
Customers
Communities
|
| Remedial Measures | Where TCC identifies that it has caused or contributed to an adverse human rights or environmental impact on rightsholders, it will provide for remediation through legitimate processes, and such remediation will be proportionate to the significance and scale of the impact. In determining the remedy, TCC will consult the affected rightsholders or their representatives. TCC takes the following steps according to its degree of involvement:
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Summary of Prevention / Mitigation / Remediation Measures

Employees

Female
Employees

Migrant Workers /
Female Migrant Workers

Communities

Indigenous
Peoples

Customers

Suppliers' Employees
(Including Migrant Workers)
| Issue | Prevention / Mitigation / Remediation Measures | |
|---|---|---|
| Whistleblower Protection | Prevention | Please refer to Table 10, Summary of TCC's Overall Grievance and Remediation Management Measures, of the Risk Identification Statement. |
| Worker Training and Education | Prevention | Description
Case Study
For more details on training and education, please refer to pages 37, 133–139, and 213 of the 2025 TCC Group Holdings Sustainability Report. |
| Working Hours / Wage and Benefits | Prevention | Wage and Benefits Management Measures
Working Hours Management Measures
Actions taken:
For more details on working hours and on wage and benefits management measures, please refer to pages 140–143 of the 2025 TCC Group Holdings Sustainability Report. |
| Occupational Health and Safety | Remediation and Prevention | In 2025, there was 1 significant penalty case for violations of Occupational Health and Safety (OHS) regulations (defined as any single penalty with an amount exceeding US$10,000). The related remediation and subsequent preventive measures are described below: Management System
Linking Occupational Safety Indicators to Remuneration
Governance and Oversight
Education and Training
Hazard Identification and Risk Assessment Process
Occupational Safety Reporting Mechanism
Right to Stop Work and Evacuate
Incident Investigation and Remediation
Case Study: Heat Hazard Project
For more details on occupational safety and health, please refer to pages 145–150 of the 2025 TCC Group Holdings Sustainability Report. |
| Freedom of Association / Collective Bargaining | Prevention |
For more details on labor-management communication, please refer to page 155 of the 2025 TCC Group Holdings Sustainability Report; for union and collective agreement participation, please refer to page 215. |
| Forced Labor / Human Trafficking / Child Labor | Prevention |
For more details on human rights protection, please refer to pages 151 and 153 of the 2025 TCC Group Holdings Sustainability Report; for risk governance and the adoption of the RBA, please refer to page 44; for the RBA Silver recognition, please refer to page 129. |
| Issue | Prevention / Mitigation / Remediation Measures | |
|---|---|---|
| Bullying and Harassment | Prevention |
For more details, please refer to page 153 of the 2025 TCC Group Holdings Sustainability Report. |
| Privacy | Prevention |
For more details, please refer to page 153 of the 2025 TCC Group Holdings Sustainability Report. |
| Diversity and Equality | Prevention | Gender Diversity and Inclusion
Maternal Protection and Friendliness
Gender Equality Advocacy
Key Data
For more details on gender diversity and inclusion, please refer to page 154 of the 2025 TCC Group Holdings Sustainability Report; for maternal protection and family care support, please refer to page 143. |
| Issue | Prevention / Mitigation / Remediation Measures | |
|---|---|---|
| Prevention | The Group's principal business entity employing migrant workers is Molicel of the Battery Energy Business. The prevention and mitigation measures for the material human rights issues affecting migrant workers are described below:
For more details on the care of migrant workers and the protection of their rights, please refer to the Molicel 2025 ESG Report. |
| Issue | Prevention / Mitigation / Remediation Measures | |
|---|---|---|
| Environmental Degradation / Waste / Land Use | Remediation and Prevention | Significant penalty cases for violations of regulations relating to this issue totaled 12, with fines of NT$28.136 million in aggregate (a significant environmental penalty event is defined as any single penalty with an amount exceeding US$10,000). The related remediation and subsequent preventive measures are described below: Environmental Management Process
Air Emissions Management
Waste Management
Case Study: Food Waste Processing Centers at the Hoping Plant and the Yingde Plant
For more details on environmental management, please refer to pages 109–110 and 115–116 of the 2025 TCC Group Holdings Sustainability Report. |
| Water Resources | Prevention | Water Resource Risk Identification
Water Withdrawal Management Mechanisms
Wastewater Management Mechanisms
For more details on water resource management, please refer to pages 113–114 of the 2025 TCC Group Holdings Sustainability Report; for environmental management targets, please refer to page 110; for site-level water risk and adaptation, please refer to page 113. |
| Biodiversity | Prevention |
For more details on biodiversity conservation, please refer to pages 157–185 of the 2025 TCC Group Holdings Sustainability Report. |
| Climate Change | Prevention | Carbon Reduction Targets and Net Zero Pathway
Physical Climate Risk and Community Adaptation
Just Transition and Community Empowerment
For more details on climate governance and risk management, please refer to pages 67–75 of the 2025 TCC Group Holdings Sustainability Report; for carbon reduction targets and the net-zero pathway, please refer to pages 31–32; for the just transition plan, please refer to pages 37–38. |
| Issue | Prevention / Mitigation / Remediation Measures | |
|---|---|---|
| Indigenous Rights | Prevention |
For more details on social engagement and local inclusion, please refer to pages 187–193 of the 2025 TCC Group Holdings Sustainability Report. |
| Issue | Prevention / Mitigation / Remediation Measures | |
|---|---|---|
| Fair Trade / Information Disclosure | Prevention | Prohibition of Unfair Competition
Product Health and Safety Management
Product Safety Traceability System
Customer grievance mechanism: please refer to Table 10 of the Risk Identification Statement. For more details, please refer to pages 79 and 88–91 of the 2025 TCC Group Holdings Sustainability Report. |
| Issue | Prevention / Mitigation / Remediation Measures | |
|---|---|---|
Human Rights
Environment
| Prevention | Management Process
Training, Empowerment, and Capacity Building
For more details on sustainable supply chain management, please refer to pages 84–87 of the 2025 TCC Group Holdings Sustainability Report; for human rights and environmental due diligence in the supply chain, please refer to page 152; for supplier nature risk assessment, please refer to pages 161–162. |