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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

 
Icon for step 1, Identify Issue
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.
 
Icon for step 2, Assess Risk
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.
 
Icon for step 3, Prevention and Mitigation
3. Prevention and Mitigation
  • Cease adverse impacts and prevent potential adverse impacts. If adverse impacts persist despite prevention measures, further mitigation is required.
 
Icon for step 4, Regular Track
4. Regular Track
  • Periodically evaluate the effectiveness of measures to prevent or mitigate adverse impacts.
 
Icon for step 5, Communication and Disclosure
5. Communication and Disclosure
  • Communicate with rightsholders and disclose all relevant information.
 
Icon for step 6, Remediation Mechanism
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

StepDescription
Step 1
  • Identification method: At this stage, international human rights and environmental risk indicators are used to make a preliminary determination of the geographic location (country) and industry characteristics (sector) of each business entity, and to assess the risk of that entity causing adverse impacts on rightsholders.

  • Grading threshold: The raw score of each international indicator is converted, according to its scale, into a standardised risk value between 0 and 1 (0 being the lowest risk and 1 the highest), and the risk value of each operating region is calculated issue by issue. Where the risk value of any country of operation for a given issue reaches 0.75 or above, that issue is included among the issues prioritised in this due diligence.

Step 2
  • Identification method: At this stage, rightsholders' views are consulted through questionnaires, focus groups and similar methods.

  • Grading threshold:

  1. For each issue, the questionnaire provides five levels for severity of impact and for likelihood of occurrence (severity: no impact / minimal impact / partial impact / considerable impact / very significant impact; likelihood: no possibility of occurrence / extremely low, 10–30% / possible, 40–60% / highly likely, 70–90% / certain to occur), which rightsholders assess issue by issue.

  2. In accordance with the UNDP Human Rights Due Diligence Training Facilitation Guide, the sum of severity and likelihood is used to determine the priority of issues; and following the Guide's recommendation, severity should be given priority even where the likelihood of occurrence is negligible.

Step 3
  • Drawing on all of the above and applying the grading thresholds set at each stage, key issues are ranked in order of priority, and this due diligence will address the key risk issues as a priority.

  • The key issue identification results are submitted by the Corporate Sustainable Development Committee to the Board of Directors.

Rightsholder Consultation Methods and Risk Identification Results

Rightsholder and Identification MethodImplementation MethodKey Issue Identification Results

Employees

  • International Indicators
  • Questionnaire
  • Focus Groups

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.

  • Varieties of Democracy (V-Dem)

  • ITUC Global Rights Index

  • UNICEF Children's Rights in the Workplace Index

  • ILO Statistics on Child Labour

  • ILO Global Estimates of Modern Slavery

  • UNODC Trafficking in Persons Data Portal

  • Note: For the grading thresholds, please see the explanation in Table 5 of the Risk Identification Statement. Child labor is, however, determined using a dedicated children's rights indicator (the UNICEF Children's Rights in the Workplace Index), with the ILO Statistics on Child Labour used as a cross-reference. The inclusion threshold is 0.60.

Step 1: International Indicators

  • Freedom of Association

  • Collective Bargaining

  • Child Labor

  • Forced Labor / Human Trafficking

Step 2: Questionnaire

Potential risks were identified jointly with employees by questionnaire, with gender factors taken into account throughout the risk identification process.

  • Scope of business entities covered by the survey: For details, please see Table 6 of the Risk Identification Statement.

  • Survey response rate (number of questionnaires returned): 94% (9,437 questionnaires returned).

  • Focus groups: Discussions focused on the just transition issues related to the cement industry and the decommissioning of the Hoping coal-fired power plant. A total of 22 participants attended, from the Taiwan cement plants of the Cement and Environmental Protection Business (Asia) and the Hoping Power Plant of the Energy for Social Transformation Business.

Step 2: All Employees

  • Whistleblower Protection

  • Worker Training and Education

  • Bullying and Harassment

  • Wage and Benefits

  • Working Hours

  • Occupational Health and Safety

Step 2: Female Employees

  • Bullying and Harassment

  • Worker Training and Education

  • Whistleblower Protection

  • Working Hours

  • Privacy

  • Diversity and Equality

  • Occupational Health and Safety

Migrant Workers

  • Questionnaire

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.

  • Survey response rate (number of questionnaires returned): 94% (178 questionnaires returned).

All Migrant Workers

  • Freedom of Expression

  • Bullying and Harassment

  • Occupational Health and Safety

  • Working Hours

  • Whistleblower Protection

  • Forced Labor / Human Trafficking

Female Migrant Workers

  • Forced Labor / Human Trafficking

  • Freedom of Expression

  • Whistleblower Protection

  • Diversity and Equality

  • Discrimination

  • Freedom of Thought, Conscience and Religion

Communities

  • International Indicators
  • Questionnaire

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

  • Environmental Degradation / Waste / Land Use

  • Water Resources

  • Climate Change

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.

  • Scope of business entities covered by the survey: Communities surrounding the Taiwan cement plants and Taiwan RMC plants of the Cement and Environmental Protection Business (Asia).

  • Taipei RMC Plant: Zhangshu Village

  • Taichung RMC Plant: Side Village

  • Kaohsiung RMC Plant: Renwu Village

  • Suao Cement Plant: Chang'an Village, Yongchun Village

  • Hoping Cement Plant: Heping Village

  • Survey response rate (number of questionnaires returned): 84%.

Step 2: All Community Residents

  • Environmental Degradation / Waste / Land Use

  • Water Resources

  • Biodiversity

  • Climate Change

Step 2: Female Community Residents (identification results identical to those for all residents)

  • Environmental Degradation / Waste / Land Use

  • Water Resources

  • Biodiversity

  • Climate Change

Indigenous Peoples

  • Questionnaire
  • Scope of business entities covered by the survey: Indigenous communities surrounding the Taiwan cement plants and Taiwan RMC plants of the Cement and Environmental Protection Business (Asia).

  • Hoping Cement Plant: Knlibu Tribe (Heping), Gukut Tribe (Hezhong), Qnragan Tribe (Heren)

  • Suao Cement Plant: Iyo Tribe

  • Survey response rate (number of questionnaires returned): 86%.

  • Indigenous Rights

  • Biodiversity

  • Environmental Degradation / Waste / Land Use

  • Water Resources

  • Climate Change

Customers

  • Questionnaire
  • Scope of business entities covered by the survey: Customers in Taiwan of the Cement and Environmental Protection Business (Asia).

  • Survey response rate (number of questionnaires returned): 81%.

  • Fair Trade / Information Disclosure

  • Climate Change

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.

  • Entities surveyed:

  1. Cement and Environmental Protection Business (Europe-Africa)

  2. Cement and Energy Storage Business (Europe-Africa)

  3. Cement and Environmental Protection Business (Asia)

  4. Asset Management Business

  5. Charging and Storage Business (Europe)

  6. Charging and Storage Business (Asia)

  7. Battery Energy Business

  8. Energy for Social Transformation Business

  9. Investment Business

  • Indicators used:

  1. Varieties of Democracy (V-Dem)

  2. ITUC Global Rights Index

  3. UNICEF Children's Rights in the Workplace Index

  4. ILO Statistics on Child Labour 

  5. ILO Global Estimates of Modern Slavery

  6. UNODC Trafficking in Persons Data Portal

  7. ENCORE

Step 1: International Indicators

Human rights:

  • Freedom of Association

  • Collective Bargaining

  • Child Labor

  • Forced Labor / Human Trafficking

Environment:

  • Environmental Degradation / Waste / Land Use

  • Water Resources

  • Climate Change

Step 2: Evaluation and Audit

  • Entities surveyed: The cement plants, RMC plants, grinding stations, distribution stations and mining subsidiaries of the Cement and Environmental Protection Business (Asia) in Taiwan, Mainland China and Hong Kong, extended in 2025 to the Longshan Cement Plant, Feng Sheng and E.G.C. Cement Corp.; and the Hoping Power Plant of the Energy for Social Transformation Business.

  • Implementation steps:

  1. Prepare the supplier self-assessment questionnaire.

  2. Conduct desktop reviews and risk-level assessments of key suppliers based on the self-assessment questionnaires returned by suppliers and publicly available information.

  3. Conduct on-site audits of potentially high-risk suppliers with lower scores.

  4. Identify high-risk suppliers based on the review results.

  • Identification results:

  1. Questionnaire response rate: 92.81%

  2. Desktop reviews: 324 suppliers

  3. On-site audits: 55 suppliers

  4. Second-party on-site audits: 3 suppliers

  5. Third-party on-site audits: 2 suppliers (conducted by Intertek)

  6. 12 high-risk suppliers identified

Step 2

Human rights:

  • Occupational Health and Safety

  • Freedom of Association

  • Collective Bargaining

  • Whistleblower Protection

Environment:

  • Environmental Degradation / Waste / Land Use

  • Water Resources

  • Climate Change

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.

  • Scope of implementation: Cement and Environmental Protection Business (Asia), Energy for Social Transformation Business

  • Proportion of new suppliers screened using environmental criteria: 100%

  • Proportion of new suppliers screened using human rights criteria: 100%

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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:
  1. Track the effectiveness of TCC's prevention, mitigation, and remediation measures for significant human rights and environmental issues.
  2. 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.
  3. 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.
ItemManagement Measures
Grievance

Reporting of Misconduct

  • TCC has established the "Reporting Mechanism for Violation of Code of Conduct" to encourage internal and external individuals to report misconduct, providing multiple channels including email, written submissions, and in-person reports. Anonymous reporting is permitted, but complete information and supporting documents are required to prevent malicious accusations. Whistleblower identities and report contents are kept confidential, and TCC undertakes that no whistleblower will be subject to improper treatment as a result of reporting. Where a report involves senior management, the whistleblower may submit it directly to the Audit Committee. TCC promotes the reporting mechanism through integrity management education and training courses to ensure that employees and external parties are familiar with the system and procedures.

  • Upon receipt of a report, the Audit Office completes registration within five working days and determines whether to accept the case based on the relevant information. Once accepted, the Audit Office forms an investigation team with relevant personnel to ascertain the facts, and submits the investigation findings and improvement recommendations to the President and the Chairman; if the case involves the President, it is submitted directly to the Chairman. Where a report is substantiated, the Audit Office collaborates with relevant units to review internal controls and operating procedures, propose corrective measures, and report regularly to the Audit Committee to prevent recurrence.

Employee Grievances

  • TCC has established grievance channels including an online friendly workplace platform and an employee feedback email, handled confidentially by dedicated personnel. Appropriate protective measures are taken in accordance with the law to protect the personal data and privacy of whistleblowers and complainants. An Appeal Review Committee has been established to ensure that cases are handled properly, professionally and impartially, and that complainants are not subject to unfair retaliation or treatment.

  • Since 2025, the Cement and Environmental Protection Business (Europe-Africa) has additionally implemented in full an anonymous, multilingual reporting service available year-round. All information received is access-controlled by a third-party unit on a need-to-know basis to safeguard whistleblower anonymity and data confidentiality, and is de-identified before being confirmed with the internal compliance department.

Suppliers

  • A whistleblowing and whistleblower protection system is in place. Where a supplier becomes aware of corruption, breach of trust, theft, misappropriation, self-dealing, fraud, or other unethical or dishonest conduct by Company personnel, the supplier may file a report under the Company's code of conduct reporting system.

Migrant Workers

  • E-One Moli Corporation of the Battery Energy Business employs migrant workers from the Philippines and Vietnam. Employee grievance channels therefore cover migrant workers, with mailboxes and forms provided in their native languages such as English and Vietnamese, and forums for migrant colleagues are held to publicize the grievance channels.

Customers

  • The Cement and Environmental Protection Business (Asia) has established the "Customer Rights Protection Policy," the "Domestic Customer Service Handling Procedures," and the "Export Customer Service Handling Procedures," and each plant has its own "Customer Service Guidelines," forming a complete grievance handling process. The Cement and Environmental Protection Business (Europe-Africa) and the Charging and Storage Business (Europe) have also established standardized grievance mechanisms, allowing customers to provide feedback through the official website, social media, and a 24-hour hotline.

  • OYAK Cement and Atlante operate dedicated mobile applications, i-Deal and myAtlante respectively, providing digital grievance services. Cases are opened immediately upon receipt, with a dedicated unit making prompt contact and providing progress updates, and with regular analysis and follow-up on improvements.

Communities

  • TCC plans to establish grievance channels in the communities where its plants are located, so that residents can raise grievances where the Company causes adverse human rights or environmental impacts. The media and format of these communication channels will be determined by consulting community residents for their feedback.

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:

  • Where the Company causes an adverse impact: take action to cease the impact and prevent its recurrence.

  • Where the Company contributes to an adverse impact: take action to cease the contributing conduct and use its leverage to mitigate any remaining impact to the greatest extent possible.

  • Where an adverse impact is caused by a business partner (such as a supplier or contractor) and is directly linked to the Company's operations: take action based on the Company's leverage over that business partner, the importance of the relationship to the Company, and the severity of the infringement.

Summary of Prevention / Mitigation / Remediation Measures

Employees

Female

Employees

Migrant Workers / 

Female Migrant Workers

Communities

Indigenous

Peoples

Customers

Suppliers' Employees

 (Including Migrant Workers)

IssuePrevention / 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

  • Purpose: TCC's net-zero and digital transformation should focus on skills development in order to succeed. Access to training and education helps employees to develop the skills needed to transition to new types of jobs or to work with new materials, processes and technologies in their existing jobs.

  • Participants: All employees.

  • Format: Online and in-person courses.

  • Key data: 344,986 training hours in 2025.

  • Training content:

  1. Development Program: Learning Ability — TCC Lyceum; Leadership — Development Program; Life Skills — Health Care and Financial Management

  2. Sustainability Program: Newcomer Training, Sustainable Learning Action Program, Institute of NextGen Sustainability (formerly the Carbon Academy)

  3. Management Program: Management Program for Mid-Level and New Managers, Leadership Impact Academy, Information Security Awareness and Management

  4. Cross-Domain Program: Generative AI Application Practices, Thinking Program, Professional Image Building and Workplace Etiquette, Global Economic and Investment Trend Observation, Effective Time Management

  5. Language Program: 1-on-1 Courses, Practical Daily Conversation, Writing Intensive Training, Current Affairs Reading, Advanced Business, Online Courses

  • Actions taken:

  1. Institute of NextGen Sustainability | Taiwan and Mainland China: The "Carbon Academy" learning zone was established at the end of 2024 to internalize carbon management as a core employee competency. To meet the carbon, water footprint, and resource recycling requirements of global supply chains, it was upgraded to the "Institute of NextGen Sustainability" in 2026. Its courses cover environmental sustainability, AI applications, just transition, and operational resilience, internalizing carbon management as a core competency of employees. The completion rate among all employees was approximately 72.25%.

  2. Skills for Green Jobs | Taiwan and Mainland China: The share of talents with skills for green jobs was 73% in 2025.

  3. Lean Certification Program | CIMPOR: Introduces the core principles and tools of Lean Production, paired with practical applications, to help employees streamline processes. Launched in 2025 and extending to all employees within three years. Around 400 participants are planned each year; from 2025 to July 2026, 158 participants had been trained cumulatively.

  4. Generative AI Application Practices | Cement and Environmental Protection Business (Asia): Aimed at supervisors and employees of the cement business entities and their subsidiaries on both sides of the Taiwan Strait. External legal experts and government-appointed instructors deliver dual-track training; the online track covers commercial information security compliance, one-stop productivity with the mainstream AI tools used on both sides of the Taiwan Strait, and AI Agent automated workflows, while in-person sessions are held at Group Operation Headquarters and the Hoping Plant, expanding from June 2026 to the Yingde Plant, the Suao Plant, and Ho-Ping Power Company. As of April 2026, cumulative attendance reached 1,807 online and 116 in person or via live stream, with 2,155 course hours in total.

Case Study

  • Electric Mining Truck Training | Hoping Quarry

  • Participants: 14 trainees, representing 100% of the drivers currently operating conventional mining trucks.

  • Schedule: Commencing in November 2025 and expected to extend into 2026.

  • Content: In response to the low-carbon transition, AI-driven autonomous electric mining trucks are being introduced. To deliver a just transition and safeguard the employment rights of existing staff, a multi-year competency shift covering four stages — fundamentals and hardware, hands-on practice and tuning, maintenance and troubleshooting, and collaboration and optimization — is being carried out to build practical capability.

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

  • TCC integrates local commodity prices and living costs to establish a fair and transparent salary structure, and dynamically optimizes remuneration levels through regular benchmarking against public data; referring to local commodity prices and living costs, TCC proposes a fair wage concept and continuously reviews local living costs and remuneration structures, moving step by step toward "decent work."

  • Employee remuneration is determined by comprehensive factors such as performance and job responsibilities, without differential treatment on the basis of gender (including sexual orientation), race, class, age, marital status, language, thought, religion, political party, place of origin, birthplace, appearance, facial features, or physical or mental disability.

Working Hours Management Measures

  • Taiwan: Employees at office locations and at overseas subsidiaries may adjust their working hours as needed, with flexible attendance intervals provided (including the subsidiaries CIMPOR, OYAK Cement, NHOA Energy, and Atlante).

  • NHOA Energy: Released the Family Working Manifesto, offering temporarily reduced working hours with proportionally adjusted salary, as well as flexible part-time plans.

  • Reduced working hours for childcare: In response to the Taipei City Government's "Reduced Working Hours for Childcare" program, employees meeting the criteria announced by the government have their daily working hours reduced by one hour with no reduction in pay; the program was launched in July 2026.

Actions taken:

  • Employee Savings Mutual Fund (Taiwan): TCC encourages employees to save, adjusting the savings amount according to age, with deposits made every January and July. The Employee Welfare Committee matches 50% of that amount, and the two are jointly deposited into the employee welfare trust account. In 2025 the fund was used by 1,363 people, with a cumulative amount exceeding NT$2 million.

  • Employee Stock Option Plan (Taiwan): TCC launched the Employee Stock Option Plan (ESOP) in 2019. Employees contribute a fixed amount from their monthly salary and the Company provides a 1:1 matching contribution, jointly deposited into a dedicated trust account. Participating employees may also apply twice a year for a lump-sum increase in their holdings, with TCC contributing an additional 10% of that self-contribution into the individual trust account. Employees retiring at the age of 60 receive multiplied contributions. The ESOP participation rate is 92%.

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

  • The Group has formulated the "Occupational Safety and Health Policy Statement" to ensure that safety management is implemented to a consistent standard across all global operating sites.

  • Sites in Taiwan and Mainland China have established "Internal Control Policies for Occupational Safety and Health Management," which apply to cross-business-group employees, dispatched outsourced workers, and contractors. The related regulations include the "Occupational Safety and Health Management Regulations," the "Occupational Safety and Health Management Plan," and the "Occupational Safety and Health Code of Practice," with a safety culture driven through behavior-oriented management.

  • Cement and Environmental Protection Business (Europe-Africa) further specifies the importance of occupational safety in its Integrated Management System Policy, with global sites committed to achieving a zero-injury vision.

Linking Occupational Safety Indicators to Remuneration

  • Performance bonuses for the management team and for first-level supervisors of the functional units at Group Operation Headquarters are subject to deductions based on occupational safety performance; at CIMPOR, 10% of variable remuneration for all employees is directly linked to occupational safety performance; OYAK Cement issues bonuses through an occupational safety and health incentive program.

Governance and Oversight

  • Occupational safety performance and improvements are regularly reviewed at senior management meetings. TCC's monthly meeting is chaired by the Chairman, where occupational safety status and improvement plans are a standing agenda item, and the resolutions reached apply to all global sites.

  • Plant-level occupational safety and health committees are in place, with labor representatives accounting for at least 33%; sites in Taiwan and Mainland China meet quarterly and monthly respectively to track implementation results.

  • Since 2025, each plant has formed a "Safety Improvement Promotion Team"; the Occupational Safety and Health Office convenes a monthly occupational safety meeting to drive and implement improvements in occupational safety at plants on both sides of the Taiwan Strait, with reward and punishment mechanisms approved by the President holding responsible personnel accountable.

Education and Training

  • Each year TCC organizes labor, occupational safety, and disaster prevention training in accordance with prevailing government regulations, and regularly arranges initial and refresher certification training for colleagues in areas such as first aid, oxygen-deficient operations, hazardous equipment, and occupational safety and health affairs management.

  • In 2025, TCC's global cross-business occupational safety education and training recorded cumulative training participants of 66,261 employees and 13,719 contractors, and cumulative training hours of 110,536 for employees and 19,030 for contractors.

Hazard Identification and Risk Assessment Process

  1. Identify all hazard sources.

  2. Identify potential risks, hazards, and consequences.

  3. Verify existing protective measures.

  4. Assess hazard risks and implement hierarchical risk control.

  5. Conduct control measures to mitigate risks.

  6. Confirm residual risks after implementing control measures and continue to track and manage them.

Occupational Safety Reporting Mechanism

  • Occupational Safety Weekly Report: routinely tracks occupational injury data, safety and health audit deficiencies and improvement results, contractor violations and handling outcomes, and the implementation of safety and health education and training.

  • Occupational Accident Reporting Platform: replaces email reporting with a platform to unify reporting channels; reporting is completed within one hour of an accident; an integrated form design has been introduced.

Right to Stop Work and Evacuate

  • Employees who identify an imminent risk of danger while performing their duties may stop work on their own initiative and evacuate to a place of safety.

Incident Investigation and Remediation

  • Work injury and fatality process: after a major occupational disaster, the incident is immediately reported to the Occupational Safety and Health Office and to superior supervisors, with contractors reporting by telephone within 30 minutes; plants in Taiwan report to the local labor inspection authority within 8 hours and plants in Mainland China within 1 hour.

  • Cause investigation: the Occupational Safety and Health Office establishes an "Occupational Accident Investigation Taskforce" to conduct on-site inspections together with labor representatives and department heads, and convenes a review meeting within one week of submitting the "Accident Prevention Report" to the President.

  • Near-miss incidents: reporting is completed on the same day and the details are registered in the "Investigation Form of Near-Miss Incidents"; the Occupational Safety and Health Office reviews the completeness of source management and improvement measures and provides an explanation at the monthly occupational safety meeting.

  • In 2025, minor occupational safety incidents at global sites involved falls, minor sprains, flying objects, falling from height, and collisions; the main causes were insufficient employee safety awareness, glass without anti-collision markings, and failure to work in accordance with regulations. Rather than addressing single points, all sites are comprehensively implementing adjustments to work content, education and training, increased audit frequency, and improved office environment design.

Case Study: Heat Hazard Project

  • Building on the supplier survey results of TCC's 2024 human rights and environmental due diligence, the "Heat Hazard Project" was launched; since 2024, a systematic high-temperature protection mechanism has been established for outdoor workers (including employees and contractors) at the plants and quarries of Cement and Environmental Protection Business (Asia).

  • Source environmental protection takes priority: dedicated shaded rest areas have been added and sufficient water dispensers or bottled water are strictly required around operational hot spots, supplemented by high-temperature operational safety advocacy.

  • High-temperature allowances are issued: from June to October each year at plants in Taiwan and from July to September each year at plants in Mainland China, calculated on the basis of work attendance days regardless of temperature levels, with a cumulative issuance of approximately NT$10.74 million.

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

  • Establishment of unions and labor agreements: TCC has legally established labor unions and signed labor agreements at all of its plants worldwide.

  • Equal protection: in Taiwan, the protection scope of all collective agreements and work rules covers all colleagues, ensuring that employees are not treated differently on the basis of their willingness to join a union or differences in conditions.

  • Labor-management meeting mechanism: each site regularly holds labor-management and union meetings to exchange views on operational and labor issues.

  • Union coverage: since 2024, the proportion of employees who have joined a union at Cement and Environmental Protection Business (Asia) and the Energy for Social Transformation Business has exceeded 90% of the total workforce.

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

  • Policy basis: TCC has established a Human Rights Policy providing for the strict prohibition of child labor, human trafficking and forced labor, and strictly complies with labor-related laws and regulations applicable in countries where the Company conducts its business. The Policy applies to the Company and its subsidiaries, joint ventures, other affiliates having any substantial controlling or subordinate relationship with the Company in Taiwan or overseas as well as suppliers and business partners; the persons covered include contract employees and interns.

  • Statement of principle: TCC strictly adheres to the principles of prohibiting child labor, human trafficking, and forced labor, and complies with all regulations relating to wages and working hours, ensuring the timely payment of fair wages while providing a working environment that promotes health and safety.

  • Preventive measures: at sites in Taiwan and Mainland China (across business groups), the Human Rights Policy forms part of the mandatory annual training program, and all employees are required to read the policy documents and complete the assessment each year; Cement and Environmental Protection Business (Europe-Africa) also incorporates human rights-related policies and requirements into the Code of Business Ethics Acknowledgement, which new employees are required to sign.

  • Human rights training hours: Cement and Environmental Protection Business (Asia), OYAK Cement, and Atlante recorded a combined total of 2,921.5 training hours and 7,464 participants.

  • Third-party audits: since 2025 TCC has adopted the Responsible Business Alliance (RBA) Code of Conduct. E-One Moli Corporation in the Battery Energy Business achieved RBA Silver recognition in 2026 following a third-party on-site audit, confirming the implementation of the five core areas of the RBA Code of Conduct: Labor, Health and Safety, Environment, Ethics, and Management Systems.

  • Grievance and remediation: please refer to Table 10 of the Risk Identification Statement.

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.

IssuePrevention / Mitigation / Remediation Measures
Bullying and Harassment

Prevention

  • Policy basis: the "Anti-Discrimination, Anti-Harassment and Anti-Bullying Complaint and Disciplinary Procedures" apply to all of TCC's global operating sites and follow the relevant ILO conventions and local laws; all global subsidiaries adopt this policy as a guiding principle in formulating their local implementation measures.

  • Preventive measures: the policy forms part of the mandatory annual training program, with all employees required to read it and complete the assessment; regular training reinforces awareness of anti-discrimination, anti-harassment, and anti-bullying. Cement and Environmental Protection Business (Europe-Africa) incorporates it into the Code of Business Ethics Acknowledgement, which new employees are required to sign.

  • Grievance and remediation: an online friendly workplace platform and an employee feedback email are available; cases are handled confidentially by dedicated personnel, with the personal data and privacy of complainants protected in accordance with the law; an appeal review committee has been established to ensure that cases are handled appropriately, professionally, and impartially and to prevent unfair retaliation or treatment.

  • Measures strengthened in 2026:

  1. Regulatory background: a dedicated chapter, Prevention of Workplace Bullying, has been added to the Occupational Safety and Health Act, and the Regulations for Workplace Bullying Prevention Measures took effect on July 1, 2026.

  2. TCC held a "Friendly Workplace Group Professional Competency Workshop," a two-day, full-day course for members of the friendly workplace group and members of the appeal review committee.

  3. The course was delivered by representatives of the competent authority, professional lawyers, and counseling psychologists, covering the laws and regulations governing employment discrimination, sexual harassment, and workplace bullying; the latest legislative trends and corporate responsibilities; case investigation procedures and practical operation; coordination, handling, and organizational restoration; and the creation of a healthy and friendly workplace. It was delivered in person and supplemented with group exercises and group investigation reports.

For more details, please refer to page 153 of the 2025 TCC Group Holdings Sustainability Report.

Privacy

Prevention

  • Policy basis: the "Anti-Discrimination, Anti-Harassment and Anti-Bullying Complaint and Disciplinary Procedures" apply to all of TCC's global operating sites and follow the relevant ILO conventions and local laws; all global subsidiaries adopt this policy as a guiding principle in formulating their local implementation measures.

  • Preventive measures: the policy forms part of the mandatory annual training program, with all employees required to read it and complete the assessment; regular training reinforces awareness of anti-discrimination, anti-harassment, and anti-bullying. Cement and Environmental Protection Business (Europe-Africa) incorporates it into the Code of Business Ethics Acknowledgement, which new employees are required to sign.

  • Grievance and remediation: an online friendly workplace platform and an employee feedback email are available; cases are handled confidentially by dedicated personnel, with the personal data and privacy of complainants protected in accordance with the law; an appeal review committee has been established to ensure that cases are handled appropriately, professionally, and impartially and to prevent unfair retaliation or treatment.

  • Measures strengthened in 2026:

  1. Regulatory background: a dedicated chapter, Prevention of Workplace Bullying, has been added to the Occupational Safety and Health Act, and the Regulations for Workplace Bullying Prevention Measures took effect on July 1, 2026.

  2. TCC held a "Friendly Workplace Group Professional Competency Workshop," a two-day, full-day course for members of the friendly workplace group and members of the appeal review committee.

  3. The course was delivered by representatives of the competent authority, professional lawyers, and counseling psychologists, covering the laws and regulations governing employment discrimination, sexual harassment, and workplace bullying; the latest legislative trends and corporate responsibilities; case investigation procedures and practical operation; coordination, handling, and organizational restoration; and the creation of a healthy and friendly workplace. It was delivered in person and supplemented with group exercises and group investigation reports.

For more details, please refer to page 153 of the 2025 TCC Group Holdings Sustainability Report.

Diversity and Equality

Prevention

Gender Diversity and Inclusion

  • Equal employment and recruitment: TCC sets targets for the proportion of female employees and strictly adheres to the principle of equal employment throughout recruitment, focusing on candidates' abilities and potential, breaking traditional restrictions based on gender, educational background, and field of study, and complying with local regulations and labor norms at each operating site to provide equal employment opportunities.

  • Eliminating recruitment bias: for recruitment at sites in Taiwan and Mainland China, a self-developed AI resume talent analysis system matches talent expertise through big data computing, effectively eliminating the unconscious bias that may arise from manual review; global sites rigorously review recruitment content, using gender-neutral expressions or non-binary language to eliminate gender stereotypes at source.

  • Gender equality governance: Atlante published its first gender equality policy in 2026, incorporating diversity, equity, and inclusion into corporate governance based on the framework of UNI/PdR 125:2022, the national standard guidelines for gender equality management in Italy, where its headquarters is located. Atlante has established a Gender Equality Committee responsible for overseeing policy implementation, KPI monitoring, and continuous improvement, ensuring that fair recruitment, equal pay, and career development mechanisms are implemented in daily management.

Maternal Protection and Friendliness

  • Nurse care services | Taiwan: pregnant colleagues are scheduled for one interview during pregnancy and one after childbirth, with occasional telephone contact to provide health education consultations.

  • Lactation rooms | All operating sites: lactation rooms are available for unlimited use during milk collection times, which are counted as regular working hours. Under Taiwan's regulations, employers grant an additional hour of lactation time each day to employees who personally breastfeed children under the age of two.

  • Paid lactation leave | Atlante: eligible colleagues in Italy are entitled to two hours of lactation leave per day.

  • Childbirth bonuses and cash gifts | Taiwan: NT$10,000 for the first child, NT$20,000 for the second, and NT$50,000 for the third; Mainland China, CIMPOR, and OYAK Cement also refer to local practices and living consumption levels to provide corresponding childbirth cash gifts and support measures.

Gender Equality Advocacy

  • In 2025, CIMPOR and OYAK Cement jointly sponsored the Turkish female boxer Dilara Yücel, promoting equal access to resources and rights for talent of all genders in sports and in wider society.

Key Data

  • The share of women in the total workforce was 23%, the share of women in management positions 18%, the share of women in junior management positions 18%, the share of women in top management positions 13%, the share of women in management positions in revenue-generating functions 25%, and the share of women in STEM-related positions 21%. The statistical scope covers Cement and Environmental Protection Business (Asia), Molicel, and NHOA Energy, but excludes the Longshan Cement Plant, the Liuzhou Plant, and Feng Sheng Enterprise Company.

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.

IssuePrevention / Mitigation / Remediation Measures
  • Freedom of Thought, Conscience and Religion
  • Freedom of Expression
  • Forced Labor / Human Trafficking
  • Bullying and Harassment
  • Discrimination / Diversity and Equality
  • Occupational Health and Safety
  • Working Hours
  • Whistleblower Protection

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:

  • Policy basis: Molicel of the Battery Energy Business refers to TCC's Human Rights Policy and has established management mechanisms in accordance with the Responsible Business Alliance (RBA) Code of Conduct, covering onboarding training, job guidance, living support, communication and grievances, and the protection of rights.

  • Workplace integration: pre-departure orientation is arranged before entry into Taiwan, covering advocacy of the RBA zero recruitment fee policy, employment rules, an introduction to the living environment, and an explanation of related rights; training for new hires on the day they report for duty covers general occupational safety and health, internal rules and regulations, codes of conduct, employment conditions, and labor-related regulations. Interpreters are arranged throughout the training so that it is delivered in a language migrant workers can understand; once on the work site, experienced colleagues of the same nationality act as job mentors.

  • Living support: well-equipped employee dormitories are provided, with shared social and rest areas and round-the-clock management personnel to implement access control and safety maintenance; a commissary is provided at the dormitory and on the Company premises, and group catering takes account of food hygiene, nutrition, and the dietary habits of different cultural backgrounds.

  • Health care: free annual health examinations are provided for migrant workers, followed by health guidance and explanations from the Company's medical personnel; resident occupational physicians conduct regular interviews to implement preventive health care and workplace health protection.

  • Diversity and inclusion: cultural experience and festival activities are held regularly, and a series of diversity and inclusion activities invites local and foreign employees to take part together, creating a friendly, inclusive, and non-discriminatory working environment; prayer rooms are provided at the employee dormitories and on the work site in respect of diverse religious beliefs.

  • Communication and grievances: company policies, employee codes, work instruction manuals, and related management rules are provided in migrant workers' native languages; physical grievance and suggestion boxes are placed in the plant area and the dormitories, alongside email, Line Official Account, a contact telephone number, a friendly communication platform, and other channels. Briefings are held regularly on government regulations and the rights of migrant workers, and symposiums for migrant workers are held regularly. The needs identified in migrant workers' work and daily life are proactively understood, then compiled, classified, and tracked in accordance with internal management procedures, with the outcome fed back to them.

  • Protection of rights: Molicel complies with the RBA Code of Conduct and relevant labor regulations to protect the working conditions and fundamental human rights of migrant workers, including lawful employment, reasonable working hours, and no restrictions of any kind on their freedom of movement. As migrant workers may ride motorcycles to and from work, the Company has strengthened its advocacy on road safety and traffic regulations to reduce commuting risk.

For more details on the care of migrant workers and the protection of their rights, please refer to the Molicel 2025 ESG Report.

IssuePrevention / 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

  • Step 1: Implement ISO systems (ISO 50001, ISO 46001, ISO 14001, ISO 14046, ISO 14064, ISO 14067).

  • Step 2: Set environmental management targets (covering energy efficiency, water efficiency, waste reduction, air pollution reduction, and greenhouse gas reduction).

  • Step 3: Develop action plans.

  • Step 4: Build employee capability.

  • Step 5: Communicate TCC's environmental protection policy and related requirements to all internal and external stakeholders (including employees, customers, affiliates, suppliers, and investors) through multiple channels, and engage with stakeholders (the TCC sustainability e-newsletter, supply chain conferences, product promotion events and launches at the RMC plants, and similar activities).

Air Emissions Management

  • TCC strictly controls process air emissions across its business entities, covering the management of stationary pollution sources, process equipment, transportation, and every other stage. It regularly commissions third-party organizations to test air quality and environmental impacts, and has set up air quality monitoring stations around its plants to ensure compliance with government emission standards.

  • The global cement plants of the cement and environmental business and Ho-Ping Power Company are all equipped with continuous emission monitoring systems (CEMS) for air pollutants, which monitor in real time the concentration and volume of air pollutants in plant emissions; sites in Taiwan and Mainland China are additionally connected in real time to the local environmental competent authorities, while CIMPOR and OYAK Cement also operate within local regulations.

  • 2030 air pollution emission intensity

Waste Management

  • TCC's global sites follow the ISO 14001 environmental management system and have established waste management procedures to implement waste sorting and management and to recycle recoverable waste, while raising awareness of and action on resource recycling through employee education and training on waste reduction.

  • 100% of OYAK Cement's plants have obtained Türkiye's Zero Waste certification.

  • Annual waste targets (Cement and Environmental Protection Business (Asia)):

  • 0.5% annual reduction in in-house household waste (cement plants and RMC plants).

  • 100% of in-house waste converted into recycled energy and resources (cement plants).

Case Study: Food Waste Processing Centers at the Hoping Plant and the Yingde Plant

  • The Hoping and Yingde plants promote food waste recycling and reuse, converting food waste into fertilizer or soil improvement materials that are returned to local neighborhoods. In 2021 the Hoping Plant established food waste recycling equipment that converts food waste from the TCC DAKA park and from food stalls in the surrounding community into soil improvement materials, provided free of charge to villagers for agriculture and gardening.

  • The Yingde Plant has built an integrated food waste treatment center that recycles food waste generated by the employee canteen and by residents of nearby villages to produce organic fertilizer, soap, hand wash, crayons, and other products. From 2020 to the end of 2025, the Hoping and Yingde plants invested a cumulative NT$24,348,857.

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

  • To comprehensively grasp water resource risks, TCC follows the Taskforce on Nature-related Financial Disclosures (TNFD) framework, prioritizing the Cement and Environmental Protection Business (Asia) and Cement and Environmental Protection Business (Europe-Africa) groups, to identify the extent to which its global quarries and operating sites depend on and affect water flow maintenance and water quality. The WRI Aqueduct Water Risk Atlas is also used to confirm the level of water stress at operating sites in Taiwan, Mainland China, Europe, Türkiye, and Africa; a total of 108 sites are located in high water stress areas.

  • The physical risk faced by each plant is primarily that water shortages could lead to rationing and production halts, while transition risk covers stricter wastewater discharge regulations, where violations could result in fines or suspension of operations. Poor management could also affect domestic and agricultural water supplies and the natural ecology in surrounding areas, with an impact on community development and the environment.

Water Withdrawal Management Mechanisms

  • Rainwater recycling and reuse (selected cement plants and RMC plants in Mainland China, CIMPOR and OYAK Cement cement plants, Ho-Ping Power Company, Hoping EcoPort).

  • Establish water metering systems to monitor water consumption data (cement plants, RMC plants).

  • Regularly inspect pipelines for aging and leaks (cement plants, RMC plants).

  • Install additional filters and monitoring equipment to increase condensate recovery (Ho-Ping Power Company).

  • Replace equipment with water-saving models and install automated landscape watering systems (Ho-Ping Power Company).

Wastewater Management Mechanisms

  • 100% of process wastewater recycled and reused with zero discharge (Taiwan RMC plants, Mainland China cement plants and the Fuzhou grinding station).

  • Establish a remote monitoring platform for runoff wastewater (Taiwan RMC plants).

  • Install shipboard sewage treatment devices, discharge systems, and equipment complying with international marine environmental protection standards, and obtain the International Sewage Pollution Prevention Certificate (ISPPC) (Ta-Ho Maritime).

  • Regularly test wastewater discharge indicators (Taiwan and 7 cement plants in Mainland China, the Liuzhou grinding station, Ho-Ping Power Company).

  • Regularly monitor wastewater treatment and pollution prevention measures, with continuous tracking and review (Taiwan and 8 cement plants in Mainland China, Ho-Ping Power Company).

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

  • Overall approach: TCC has established a Biodiversity Group under the Corporate Sustainable Development Committee. Following the TNFD LEAP methodology, it systematically inventories the dependencies and impacts of the global operational value chain on natural capital, establishes management strategies and priorities for action, identifies risks and opportunities, and finally conducts the related financial assessments, elevating nature issues from the level of environmental management to that of corporate strategy and risk governance. Since 2023, TCC has progressively aligned its nature conservation actions with the international TNFD transition plan guidance and published a TNFD Report presenting the related performance, responding to international nature initiatives with concrete actions and results.

  • Assessment scope: the analysis boundary has expanded from the Hoping 3-in-1 industrial park (port, power plant, and cement plant) in 2023, to Cement and Environmental Protection Business (Asia) and its suppliers in 2025, and further in 2026 to the global owned operating sites of all business groups together with the suppliers of Cement and Environmental Protection Business (Asia), totaling 390 sites across Taiwan, Mainland China, Türkiye, Portugal, Cameroon, Ivory Coast, and other locations. The scope of analysis covers upstream (quarries, port areas), owned operations (quarries, cement plants, RMC plants, grinding stations, offices, gypsum plants, dry-mix mortar plants, paper bag plants, renewable energy sites, battery plants, aggregate plants), downstream (shipping stations, port areas, environmental technology companies), and adjacent areas within two kilometers of these sites; supplier sites are those on the Science Based Targets Network (SBTN) high-risk list of Cement and Environmental Protection Business (Asia).

  • Comprehensive analysis and priorities for action: TCC gives priority to managing sites of very high (VH) natural sensitivity. Because VH sites are located close to nationally important ecosystems and contain many threatened species, poor management can trigger degradation of environmental resilience, readily aggravating the impact of natural disasters and causing operational losses. TCC's VH sites are concentrated in upstream quarries and owned plants, and are further cross-assessed against ENCORE level 5 operational types in order to understand the dependencies and impacts of different types of operation on natural capital. Adaptation strategies and action measures are formulated at the same time, so as to reduce environmental impacts and help restore biodiversity in the surrounding areas.

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

  • TCC completed its SBT target setting in 2020, becoming the first cement company in East Asia to commit to and pass SBTi validation. In January 2025, both Cement and Environmental Protection Business (Asia) and Cement and Environmental Protection Business (Europe-Africa) passed the 1.5°C validation and committed to a 2050 net-zero plan. In March 2026, TCC further submitted net-zero targets on a group-wide, consolidated financial statement basis, which are under official SBTi validation; in the same month, the Charging and Storage Business (Europe) also completed the setting of its near-term 1.5°C target.

  • In 2024, TCC completed the "2050 Net Zero Pathway for the Global Cement and Environmental Business," covering all sites in Taiwan and Mainland China as well as CIMPOR and OYAK Cement. It follows the SBT 1.5°C methodology and the ISO IWA 42 net-zero guidelines and refers to the IEA's net-zero pathway report and World Energy Outlook, with alternative clinker, alternative raw materials, alternative fuels, waste heat recovery, process improvements, renewable energy, and carbon capture as its carbon reduction strategies, and natural carbon sinks as a feasible option for net-zero carbon removal. TCC will continue to plan a group-wide net-zero pathway in 2026.

Physical Climate Risk and Community Adaptation

  • TCC analyzed its operating sites in Taiwan and Mainland China with reference to national meteorological observations, the IPCC SSP1-2.6 low-emission and SSP5-8.5 very high emission scenarios, and disaster risk databases, quantifying the likelihood and severity of physical risks. For the CIMPOR and OYAK Cement plants, the World Resources Institute (WRI) Aqueduct Global Flood Analyzer was used to review the flood risk that each site could face from extreme precipitation events under different scenarios in 2030 and 2050.

  • In response to the frequency and intensity of extreme precipitation events, TCC has built detention and desilting basins and installed two-meter earth embankments on quarry slopes to mitigate the impact of flooding; the RMC plants have emergency response procedures in place, the cement plants have typhoon and flood response plans, and flood control teams have been formed at the plants to hold regular drills and step up inspections. TCC will conduct regular flood disaster simulations for these sites in the future to enhance the plants' adaptation measures.

Just Transition and Community Empowerment

  • Through internal workshops, TCC has inventoried the stakeholders affected by the net-zero transition and identified employees, local communities, suppliers, and consumers as those principally affected at present, and has launched a number of action strategies. In line with the needs of grid stability in Taiwan, Ho-Ping Power Company will decommission its coal-fired units no later than 2040.

  • TCC has launched the "AI Empowerment Initiative," reaching He-Ping Elementary School and Dong'ao Elementary School near its production sites to learn about generative AI, the operation of unmanned inspection drones, and smart quarries together with teachers and students. Over the summer the program extended to Heping Village and Aohua Village, helping mothers and elders in the community master mobile AI search and real-time translation and bridge the digital divide, and helping middle-aged residents use AI tools to enhance their workplace capabilities.

  • TCC DAKA Open Ecological Circular Factory is open 24 hours a day and operates on a non-profit basis, with its market supporting entrepreneurship among tribal residents through low-cost stalls. TCC Green Energy has combined its solar sites in the Budai and Yizhu areas of Chiayi with aquaculture, establishing a dedicated aquaculture team to work with local aquaculture farmers and pioneering the first traceability certification for an aquavoltaic site in Chiayi County.

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.

IssuePrevention / Mitigation / Remediation Measures
Indigenous Rights

Prevention

  • Communication and engagement mechanisms: in 2019, in response to the expectations of the Hualien County Government, TCC proposed a privately initiated BOO project for cement kiln co-processing of Hualien's household waste. Faced with concerns from the surrounding tribal communities, TCC made field visits, took part in tribal village games and traditional festivals, and entered into dialogue with opinion leaders, establishing channels of communication with the community and opening the gates of the Hoping Plant by reorganizing part of the plant area for public access — and so TCC DAKA was born.

  • Tribal co-decision governance: the Hoping Sustainable Charity Foundation was established in October 2022. Following the tribal tradition of collective decision-making, the Heping Village chief and three indigenous chairpersons serve as its directors, and dedicated funds are used to support families facing accidents, misfortune, or hardship. In 2023 the initiative was extended to Ho-Ping Power Company with the establishment of a "Maritime Emergency Relief Fund," which supports fishermen and their families under the Suao District Fishermen's Association.

  • Local empowerment and employment: TCC upholds local hiring and has established the DAKA Market as an incubator for entrepreneurship among tribal residents, providing employment opportunities outside manufacturing together with training in space and display design, photography, and marketing to help market partners strengthen their operating capabilities; through digital empowerment, some partners have successfully opened up e-commerce markets and even started businesses elsewhere. On a non-profit basis, TCC allocates a percentage of the revenue from DAKA guided tours and market administration, together with a set percentage contributed by partner companies, to a fund that supports local education and emergency relief.

  • Community resilience and emergency support: after the earthquake of April 3, 2024 (the '0403 earthquake'), TCC converted the former office building of the Hoping Plant into a temporary shelter, designing barrier-free spaces, a lactation room, and other facilities for the needs of the elderly, women, and children, and had it incorporated into the emergency shelter system of the Xiulin Township Office — the first instance of a company proactively supporting disaster prevention. TCC has also established a Home Repair Service Center which, in view of the scarcity of repair resources in rural areas, provides basic parts free of charge and assists with repairs; the service was extended to the Suao Plant in 2024. The Hoping Care Bus, launched in 2023, transports elderly residents and villagers of Heping Village to and from town every day to meet their medical, administrative, and shopping needs, and added a stop at Aohua Village in August 2025.

For more details on social engagement and local inclusion, please refer to pages 187–193 of the 2025 TCC Group Holdings Sustainability Report.

IssuePrevention / Mitigation / Remediation Measures
Fair Trade / Information Disclosure

Prevention

Prohibition of Unfair Competition

  • Maintaining a reasonable order of commercial competition is an important commitment of ethical management. TCC does not tolerate any employee undermining the mechanism of free market competition through practices that violate the Fair Trade Act, such as monopolies or coordinated market allocation.

Product Health and Safety Management

  • TCC pays close attention to and fulfills its duty to safeguard customer rights, referring to the OECD Guidelines for Multinational Enterprises in exercising strict control over customer health and safety in relation to its products and services, as well as over marketing and labeling.

  • The global plants of the cement and environmental business conduct regular product testing to ensure that products meet health and safety standards in use. Every business group has adopted quality management procedures, product information is clearly labeled in the local language, comprehensive product safety information is provided to customers through product labels, packaging bags, and delivery documents, and Safety Data Sheets (SDS) are available for reference.

Product Safety Traceability System

  • Cement and Environmental Protection Business (Asia) has established a "Product Safety Traceability System" in Taiwan, incorporating AI assistance and user-oriented design. Customers can scan a QR code to access the mixing ratios, sources, carbon emission intensity, and inspection reports of concrete raw materials, disclosing product information to standards comparable with those for food traceability; integrated with the e-commerce app, the "TCC News" feature has also been launched.

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.

IssuePrevention / Mitigation / Remediation Measures

Human Rights

  • Child Labor
  • Forced Labor / Human Trafficking
  • Freedom of Association
  • Collective Bargaining
  • Occupational Health and Safety
  • Whistleblower Protection

Environment

  • Environmental Degradation / Waste / Land Use
  • Water Resources
  • Climate Change

Prevention

Management Process

  • Step 1 Risk assessment: supplier basic data is collected and verified, with initial screening and qualification assessment carried out through the Procurement Portal; AI models are used for risk assessment and early warning, and a product life-cycle approach is applied to identify sustainability risks at each stage of the value chain.

  • Step 2 Sustainability assessment and audit: significant suppliers undergo desk assessment and risk grading through self-assessment questionnaires and publicly available information; on-site audits are further conducted for potentially high-risk suppliers with lower scores.

  • Step 3 Corrective actions and improvements: high-risk suppliers are guided by dedicated personnel to submit improvement plans and are required to submit a corrective action plan (CAP) within three months; the following year they are given priority in capacity-building projects such as sustainability governance workshops and are reviewed. Where a supplier fails to complete improvements within three months of counseling, an internal proposal is made to terminate the transaction and replace the supplier. Suppliers that still have room for improvement remain in the business relationship but are designated for focused guidance, receiving education and training through the online learning platform, with strengthened supervision and continuous tracking of improvement progress and effectiveness; where the standard is still not met within twelve months (a score below 60), an internal proposal is made to terminate the transaction and replace the supplier.

Training, Empowerment, and Capacity Building

  • Capacity building program (a semi-annual project): comprising online and in-person coaching courses.

  1. Environmental and climate aspects: implementing ISO 14001 and ISO 14064 and holding environmental workshops.

  2. Quality and operational aspects: combining ISO 9001 with occupational safety workshops.

  3. Responsibility and governance aspects: promoting ISO 20400 sustainable procurement and responsible business conduct training, integrating human rights, ethics, and sustainable decision-making into core operations.

  • Product carbon footprint intensive training camp: helping suppliers secure third-party verification resources and enhancing their practical capabilities in product carbon footprint inventories and carbon reduction strategies.

  • Sustainability governance workshop: helping SME suppliers and medium-to-high-risk significant suppliers establish sustainability management systems and set policies and targets.

  • Supplier sustainability learning platform: a dedicated learning platform has been established covering occupational safety heat hazards, working hours, and physical and mental well-being, with net-zero planning and management and carbon knowledge training introduced.

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.