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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

  • TCC Group Holdings due diligence approach primarily references the United Nations Guiding Principles on Business and Human Rights, the Human Rights Due Diligence Training Facilitation Guide, the EU Corporate Sustainability Due Diligence Directive and its Annex, the OECD Due Diligence Guidance for Responsible Business Conduct, and the OECD Guidelines for Multinational Enterprises

  • TCC reviews its overall human rights and environmental risks at least every three years. The first human rights and environmental due diligence review was conducted in 2024. The scope of that due diligence will be expanded to more business entities in 2025 and will be continuously and regularly implemented thereafter.

  • TCC Group Holdings 2025 Human Rights and Environmental Due Diligence Risk Identification Statement

Human Rights and Environmental Due Diligence Process

  • Collect various human rights and environmental issues that may affect different rightsholders

  • Referencing guidelines and conventions from the United Nations, EU, OECD, and the International Labor Organization to compile relevant issues

  • Consult rightsholders to assess the risks to human rights and environmental matters. To effectively assess risk, prioritize the most significant risks based on their severity and likelihood

  • The rightsholders consulted in this due diligence include their employees, surrounding community residents, indigenous peoples, migrant workers, customers, etc

  • Cease adverse impacts and prevent potential adverse impacts. If adverse impacts persist, despite prevention measures, further mitigation is required

  • Periodically evaluate the effectiveness of measures to prevent or mitigate adverse impacts

  • Communicate with rightsholders and disclose all relevant information

  • Provide remedial measures for any adverse impacts that have occurred

  • Establish a company grievance mechanism

Right holder Consultation: Identification and Methods

Right holder GroupsConsultation MethodBusiness Unit Coverage

All Right holders

International Human Rights and Environmental Risk Indicators
The following international indicators are used to review the risks of human rights and environmental issues in the countries where the business entities operate. For details on the human rights and environmental issues corresponding to each indicator, please see the TCC Group Holdings 2025 Human Rights and Environmental Due Diligence Risk Identification Statement.

  • Varieties of Democracy(V-Dem) Human rights index
  • Freedom House Index
  • ITUC Global Rights Index
  • ENCORE
  • Operations Headquarters
  • Cement & Environmental Business (Europe/Africa)
  • Cement & Environmental Business (Asia)
  • Asset Management & Development Business
  • Charging & Storage Business (Asia)
  • Battery Energy Business
  • Energy for Social Transformation Business
  • Investment Business

Employee

Questionnaire
Survey Response Rate (Number of Questionnaires Returned): 94% (9,437 questionnaires returned).

  • Operations Headquarters
  • Cement & Environmental Business (Asia)
  • Asset Management & Development Business
  • Charging & Storage Business (Asia)
  • Battery Energy Business
  • Energy for Social Transformation Business
  • Investment Business

Focus Groups
Discussions focused on the just transition issues related to the cement industry and the decommissioning of the Ho-Ping thermal coal power plant. A total of 22 people were invited to participate, including individuals from the Taiwan cement plants of the Cement and Environmental Business (Asia) and the Ho-Ping Power Plant in Taiwan from the Energy for Social Transformation Business.

  • Operations Headquarters
  • Cement & Environmental Business (Asia): Taiwan Cement Plants
  • Energy for Social Transformation Business

Migrant Workers

Questionnaire
Survey Response Rate (Number of Questionnaires Returned): 94% (178 questionnaires returned).

Battery Energy Business

  •  E One Moli Corporation
  • Molie Quantum Energy Corporation

Community

Questionnaire
Survey Response Rate: 84%

Surrounding communities to the Suao Cement Plant, Hoping Cement Plant, Taiwan RMC Plants, part of the Cement and Environmental Business (Asia).

  • Taipei RMC Plant: Zhangshu Village
  • Taichung Products Plant: Side Village
  • Kaohsiung Products Plant: Renwu Village
  • Suao Cement Plant: Chang'an Village, Yongchun Village
  • Hoping Cement Plant: Heping Village

Indigenous

Questionnaire
Survey Response Rate: 86%

Surrounding Indigenous communities of the Suao Cement Plant and Hoping Cement Plant, both part of the Cement and Environmental Business (Asia).

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

Customers

Questionnaire
Survey Response Rate: 81%
Customers in Taiwan of the Cement and Environmental Business (Asia).

Supply Chain

Review of International Human Rights and Environmental Indicators
The following international indicators are used to review the risks of human rights and environmental issues in the countries where the business entities operate. For details on the human rights and environmental issues corresponding to each indicator, please see the TCC Group Holdings 2025 Human Rights and Environmental Due Diligence Risk Identification Statement.

  • Varieties of Democracy(V-Dem) Human rights index
  • Freedom House Index
  • ITUC Global Rights Index
  • ENCORE
  • Operations Headquarters
  • Cement & Environmental Business (Europe/Africa)
  • Cement & Environmental Business (Asia)
  • Asset Management & Development Business
  • Charging & Storage Business (Asia)
  • Battery Energy Business
  • Energy for Social Transformation Business
  • Investment Business
Questionnaire Survey
Survey Response Rate: 96%
Tier 1 key suppliers/contractors in Taiwan for the Cement & Environmental Business (Asia).

Key Issue Identification Results

Identification and Assessment MethodsKey Issue Identification Results
International Human Rights and Environmental Risk Indicators
  • Freedom of Association
  • Collective Bargaining
  • Forced Labor / Human Trafficking
  • Bullying and Harassment
  • Child Labor
Employee Questionnaire and Focus Groups

All Employee

  • Whistleblower Protection
  • Worker Training and Education
  • Bullying and Harassment
  • Working Hours
  • Collective Bargaining
  • Occupational Health and Safety

Female Employee

  • Bullying and Harassment
  • Worker Training and Education
  • Whistleblower Protection
  • Working Hours
  • Privacy
  • Diversity and Equality
  • Occupational Health and Safety
Migrant Workers Questionnaire

All Migrant Workers

  • Freedom of Expression
  • Bullying and Harassment
  • Occupational Health and Safety
  • Working Hours
  • Forced Labor / Human Trafficking

Female Migrant Workers

  • Forced Labor / Human Trafficking
  • Freedom of Expression
  • Whistleblower Protection
  • Diversity and Equality
  • Freedom of Thought and Conscience
Community Questionnaire
  • Environmental degradation, waste management, land use
  • Water resources
  • Biodiversity
  • Climate change
Indigenous Questionnaire
  • Indigenous rights
  • Biodiversity
  • Environmental degradation, waste management, land use
  • Water resources
  • Climate change
Customers Questionnaire
  • Fair trade/information disclosure
  • Climate change
Supply Chain Survey
  • Occupational health and safety
  • Bullying and harassment
  •  Climate change
  • Working hours
  • Environmental degradation/ waste/land use
  • Freedom of Association
  • Collective Bargaining
  • Forced Labor
  • Human Trafficking
  • Child Labor

Prevention/Mitigation of Key Human Rights and Environmental Issues and Remedial Measures for Existing Impacts

  • 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.

  • Please refer to the table below for prevention, mitigation, and remediation measures for key issues. For detailed information, please refer to the 2024 TCC Sustainability Report.

  • The following key points will be the focus of the TCC GROUP HOLDINGS 2024 Human Rights and Environmental Due Diligence Report scheduled for release in the fourth quarter of 2025:

  1. Track the effectiveness of TCC's prevention, mitigation, and remediation measures for significant human rights and environmental issues.

  2. Case Studies of Taiwan Cement Corporation's Responses to Human Rights and Environmental Incidents: 

    (a)    Ho-Ping Power Plant purchasing Russian coal incident
    (b)    Hualien County Cement Kiln Co-processing Waste Private BOO Project overturned by Taiwan Supreme Administrative Court for retrial
    (c)    Land use permit case of Area F at the Chiayi Aquavoltaics Phase I site
    (d)    Taiwan RMC Plant Tainan Branch partial wastewater suspended solids exceeding standard incident
    (e)    Molie Quantum Energy Corporation (MQE) Battery Plant fire incident

  3. 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.
     

Summary of Prevention/Mitigation/Remediation Measures

Employees

Female

Employees

Migrant Workers/
Female Migrant Workers

Community

Indigenous

Peoples

Customers

Suppliers

(Migrant workers)

IssuePrevention/Mitigation/Remediation Measures
Whistleblower Protection

Prevention

  • TCC promotes reporting of misconduct by anyone connected to the Company through its "Reporting Mechanism for Violation of Code of Conduct," accepting reports via email, written submissions, or in person. TCC also promotes the whistleblowing mechanism through integrity management education and training courses to ensure that employees and external personnel are familiar with the system and procedures. Whistleblower identities and report details are kept confidential, and retaliation is strictly prohibited. If it involves senior managers, reports can be made to the Audit Committee.

  • The Audit Office registers received cases within five days and verifies their acceptance based on relevant information. Upon acceptance, an investigation team is formed with relevant personnel to ascertain facts, and findings and recommendations are submied to the President and Chairman. If the case involves the President, the report will be submitted directly to the Chairman. If a whistleblowing case is verified as true, the Audit Office will collaborate with relevant departments to review internal controls and operational procedures, propose corrective measures, and regularly report to the Audit Committee to prevent recurrence.

  • Taiwan Cement Corporation (TCC) has established the "Employee Grievance and Handling Guidelines" and provides multiple channels for employees to voice their opinions and file grievances. All submissions are handled by a dedicated unit. These channels include a dedicated email, hotline, fax, letterbox, and internal system platforms.

  • CIMPOR has established a third-party whistleblowing mechanism, managed by an independent external unit through the online whistleblowing platform Ethi.co. The platform operates year-round, regardless of time, location, or time zone, supports multiple languages. Employees and suppliers can submit reports via telephone, email, or the online platform (cimporglobal.speakup.report).

Worker Training and Education

Prevention

  • TCC develops worker training and education projects such as Employee Development Programs and TCC Carbon Academy.

  • For more details, please refer to pages 161-168 of the 2024 TCC Sustainability Report.

Working Hours /
Wage and Benefits

Prevention

Details regarding the TCC's remuneration policy, performance appraisal system, flexible hours, and agile working can be found on pages 169-172 of the 2024 TCC Sustainability Report.

Occupational Health and Safety

Remediation

  • In 2024, the Cement & Environmental Business (Asia) and (Europe/Africa) recorded a combined total of nine high-consequence work-related injuries.

  • Details regarding the Work Injury, Fatality, and Near-Miss Incident Investigation & Improvement Process can be found on pages 176 of the 2024 TCC Sustainability Report.

Prevention

TCC conducts hazard identification and risk assessment for routine and non-routine operations. This involves evaluating hazardous workplaces and assessing the severity and frequency of OHS risks across various processes and activities to calculate OHS risk indicators. From identified hazards, TCC assesses their OHS risks and implements relevant measures, considering regulations and the effectiveness of existing controls.


Hazard Identification and Risk Assessment:

  • Step 1: Identify all hazard sources

  • Step 2: Identify potential risks, hazards, and consequences

  • Step 3: Verify existing protective measures

  • Step 4: Assess hazard risks and implement hierarchical risk control

  • Step 5: Conduct control measures to mitigate risks

  • Step 6: Confirm residual risks after implementing these control measures

For more details, please refer to pages 173-179 of the 2024 TCC Sustainability Report.

Freedom of Association / Collective Bargaining

Prevention

To foster a harmonious labor-management relationship, TCC has established labor unions across all its Taiwan plants and signed collective bargaining agreements. In 2024, the proportion of all employees who joined a union across TCC's cement businesses in Taiwan and Mainland China, as well as Ho-Ping Power Plant, was 91% of the total workforce. To protect the rights of all employees in Taiwan, the terms of both collective agreements and work rules apply to all employees, who are not treated differently based on any factors, including their membership status or willingness to join a union. TCC holds quarterly labor-management and/or union meetings for open communication and discussion on various issues.

Forced Labor / Human Trafficking/ Child Labor

Prevention

  • TCC firmly prohibits child labor, human trafficking, and forced labor, and complies with all relevant wage and working hour regulations to ensure timely payment of fair living wages. At the same time, we foster a safe and healthy work environment, supporting employees in maintaining good physical and mental health and work-life balance.

  • For more details about human rights protection, please refer to pages 180-184 of the 2024 TCC Sustainability Report.

IssuePrevention/Mitigation/Remediation Measures
Bullying and Harassment

Prevention

TCC values employee rights and promotes a safe, inclusive workplace. An "Anti-discrimination and Anti-harassment Policy" guides employees in preventing and addressing misconduct. In Q1 2025, anti-bullying measures will be added into the "Anti-discrimination, Anti-harassment, and Anti-bullying Policy," strictly banning all forms of bullying and providing secure grievance channels. Training and promotion further support awareness and a respectful work environment.

Privacy
Diversity and Equality

Prevention

  • TCC's construction materials business involves physically demanding roles, often attracting more male applicants. To reduce groupthink, TCC sets female representation targets, with NHOA Energy and Atlante aiming to increase female engineers tenfold.

  • Food is a gateway to cultural understanding. TCC fosters cross-cultural exchange through activities like sharing Italian cuisine at Christmas and Taiwanese snacks at birthdays. In 2024, TCC co-hosted "Dante Movie Night" with the Italian Economic, Trade and Cultural Promotion Office, pairing Italian food with casual networking.

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

Prevention

  • In 2024, the Battery Energy Business at E One Moli Corporation and Molie Quantum Energy Corporation enhanced diversity and inclusion for foreign colleagues, offering cultural experiences, Mandarin courses, and 24-hour translation and life assistance to aid their integration into Taiwan's workplace.

  • E One Moli Corporation and Molie Quantum Energy Corporation also uphold human rights by enforcing zero recruitment fees and ensuring equal promotion and career development opportunities for foreign staff, thereby demonstrating strong commitment to ethnic integration.

  • For more details, please refer to the Molicel 2024 ESG Report.

IssuePrevention/Mitigation/Remediation Measures
Water Resources

Remediation

  • Violation of water pollution regulations: 2 incidents (Cement & Environmental Business - Taiwan).

  • Following a late-2024 overflow incident at the Tainan RMC Plant, where heavy rain caused suspended solids to exceed standards, TCC immediately reported the event, initiated response protocols, and completed cleanup. By Q1 2025, initial improvements like retention ponds and pre-treatment facilities were completed, followed by comprehensive actions including upgrading the water treatment system, extending risk assessments to other plants, and strengthening early warning capabilities.

Prevention

  • Although the cement industry is not considered water-intensive, TCC proactively strengthens its water management. Following the Task Force on Nature-related Financial Disclosures (TNFD) framework, TCC identifies its dependencies on surface and groundwater, water flow, and water quality to comprehensively understand resource risks.

  • In 2024, a priority assessment was conducted on Taiwan's quarry and cement sites. Using the WRI Aqueduct Water Risk Atlas, TCC assessed all locations in Taiwan and Mainland China, identifying three cement plants—Anshun, Guigang, and Huaying—as being in high-risk, water-stressed regions.

  • Key risks for these plants include potential production halts from water shortages (physical risk) and stricter discharge regulations (transition risk). Violations could lead to fines or stoppages with maximum daily losses of up to NT$10.98 million (approx. US$366,000). Poor management could also impact local community and agricultural water supplies.

  • As this assessment expands to CIMPOR and OYAK CEMENT locations in 2025, TCC will further set risk mitigation targets, implement tiered resource management at its production sites, and begin promoting low-water-impact products.

  • For more details, please refer to pages 94-95 of the 2024 TCC Sustainability Report.

Waste Management

Remediation

  • One violation of a waste management regulation (Cement & Environmental Business - Mainland China): Improper storage of hazardous waste in violation of national environmental standards.

  • Corrective Actions: Operations are now conducted in strict compliance with all applicable laws and regulations.

Prevention

  • TCC's waste management is based on the ISO 14001 environmental system. For in-plant treatment, bottom ash, waste oil, and waste refractory materials are fed into rotary kilns as alternative raw materials and fuels. Shredded employee domestic waste, plastics, rubber, and paper are also utilized as alternative fuels. Off­site, qualified contractors recycle valuable metals like scrap iron for reuse in steel plants. Based on these management regulations, TCC's global operations are setting their own waste reduction targets to enhance group-wide resource recycling efficiency.

  • For more details, please refer to pages 98-103 of the 2024 TCC Sustainability Report.

Environmental Degradation

Prevention

  • Assessment and Management Based on Nature-related Financial Disclosures (TNFD) and SBTN by the Cement & Environmental Business (Europe/Africa and Asia).

  • For more details, please refer to pages 124-158 of the 2024 TCC Sustainability Report.

Biodiversity
Land Use
Climate Change

Prevention

  • TCC unveiled the new " Net Zero Pathways for Cement and Concrete Business Units Worldwide".

  • In January 2025, TCC's Taiwan and Mainland China sites, along with its European subsidiaries CIMPOR and OYAK CEMENT, all achieved the SBT 1.5°C validation and committed to setting 2050 net-zero plans.

  • For more details, please refer to pages 51-60 and 82-104 of the 2024 TCC Sustainability Report.

IssuePrevention/Mitigation/Remediation Measures
Indigenous Rights

Prevention

  • Opened in January 2020, TCC DAKA Open Ecological Circular Factory (TCC DAKA) is Taiwan's first open tourist factory in heavy industry. Its creation followed a 2019 Hualien County Government invitation for TCC to manage household waste via a private BOO (Build-Operation-Own) project for cement kiln co-processing, initiating TCC's industry and community inclusion efforts.

  • An-ping Chang's philosophy that "a factory cannot exist isolated; it is always connected with surrounding communities. A factory should become a part of society and local life," TCC opened the Hoping Plant as a non-profit initiative, aiming to coexistence with the community and fostering dialogue between industry and society.

  • Activities, social networks, and visiting opinion leaders serve as vital communication channels. By integrating residents' expectations and needs into its strategies across public welfare, co-prosperity, and transformation, TCC actively works to build a resilient community.

  • Affected by earthquakes and typhoons, Hualien was the focus of social engagement in 2024. TCC extended care to stakeholders near the Hoping Eco-friendly Low-carbon Energy Park by promoting the Carbon Reduction Parent-Child Bankbook, utilizing social media to encourage online purchases for eco-friendly local brands. TCC also strengthens the community safety net with home repair services, the Hoping Care Bus, and the Hoping Sustainability Charity Foundation.

  • For more details, please refer to pages 185-191 of the 2024 TCC Sustainability Report.

IssuePrevention/Mitigation/Remediation Measures
Fair Trade/ Information Disclosure

Prevention

  • To safeguard client rights, TCC has a robust complaint procedure. All complaints are internally reviewed, resolved, and clients are informed of final outcomes. Furthermore, TCC employees, guided by the Statement of Integrity and Ethical Conduct, are bound by strict confidentiality. This includes protecting all non-public information that could harm company or client interests, ensuring personal data security.

  • For more details, please refer to pages 77-79 of the 2024 TCC Sustainability Report.

IssuePrevention/Mitigation/Remediation Measures
Occupational Health and Safety, Bullying and Harassment, Climate Change , Working Hours, Environmental Degradation/ Waste/Land Use, Freedom of Association, Collective Bargaining, Forced Labor, Human Trafficking, Child Labor

Prevention

  • Obtained ISO 20400 Sustainable Procurement Certification.
  • TCC implements two core strategies — Sustainable Supplier Management & Localized and Green Procurement — under the Board of Directors oversight. The Supply Chain Management Department integrates initiatives across TCC and subsidiaries, with regular progress regularly reported and discussed by the CSO at Chairman-led operational meetings. The department head also provides periodic updates to the Board. The sustainable supply chain mechanism prioritizes cement business in Taiwan and Mainland China, distribution stations in Hong Kong, and key mining subsidiaries, with projects periodically reviewed by the Sustainable Development Commi­ee to ensure that procurement policies comply with the Company's sustainability requirements. By 2025, this approach will extend to subsidiaries Feng Sheng, E.G.C., and Ho-Ping Power Plant, and gradually including suppliers from other subsidiaries and CIMPOR and OYAK CEMENT.

  • Cement & Environmental Business (Europe/Africa): Conducting Third-party Due Diligence on potential partners via the Refinitiv Platform (suppliers, customers, applicants) to screen for sanctions or compliance risks.

  • For more details, please refer to pages 71-76 of the 2024 TCC Sustainability Report.