Natural-Related Dependency, Impact, Risk, and Opportunity Assessment

As a leading telecommunications provider in Taiwan, Chunghwa Telecom recognizes that its business operations are closely connected to the natural environment and places great importance on environmental stability. Given the close interaction between its operational activities and the natural environment, and the resulting impacts on stakeholders, Chunghwa Telecom follows the TNFD final disclosure framework and analytical methodology, incorporates input from nature-related stakeholders, and systematically assesses the impacts of its operations on natural ecosystems and stakeholders. This serves as an important foundation for advancing the management of nature-related risks and opportunities and actively promoting the harmonious coexistence of people and nature. In 2025, we further expanded the scope of the assessment beyond the parent company to include priority group subsidiaries in the analysis. We reviewed the Group's business activities' dependencies and impacts on natural capital and, together with the current status of nature-related risks and opportunities identified during the year, assessed their financial impacts to strengthen the Chunghwa Telecom Group's ability to manage nature-related risks and opportunities.

• Introduction and Adoption of the LEAP Approach

Taking into consideration the characteristics of Taiwan's natural environment and the availability of relevant data, and following the LEAP approach recommended by TNFD, we defined the assessment scope, reviewed and iteratively applied the four key steps of Locate, Evaluate, Assess, and Prepare, and developed localized Locate and Evaluate analytical processes to enhance the relevance of the analysis results to Taiwan's local context. As the scope of analysis expanded, in 2025 we incorporated Group subsidiaries into the assessment, and further incorporated Chunghwa Telecom's linear sites, such as submarine cable landing sites, into the Locate process in the subsequent step.

Under the LEAP approach, the Locate phase focuses on identifying and prioritizing areas where the organization depends on and impacts nature, linking operational activities with natural systems through spatial analysis. The Evaluate phase further analyzes the identified nature-related dependencies and impacts. The Assess phase evaluates potential nature-related risks and opportunities arising from these dependencies and impacts from a business operations perspective. The Prepare phase focuses on responses to and disclosure of material nature-related issues. In accordance with this approach, during the Locate phase, the Company analyzed the overlap between Chunghwa Telecom's operating sites, Group subsidiaries, key value chains, and nature-sensitive areas. During the Evaluate phase, we conducted a structured assessment of their dependencies and impacts on nature. During the Assess phase, TNFD categorizes nature-related risks into physical risks¹, transition risks², and systemic risks³. Based on the dependencies and impacts identified during the Evaluate phase, we assessed the nature-related risks that our operations may face. Physical risk issues focus on analyzing the potential impacts of changes in the natural environment on operations, while transition risks consider external changes such as overall operational conditions, regulatory and policy developments, and market trends. At the same time, we examined the potential for nature-related opportunities⁴ created through the promotion of nature risk management and conducted a materiality assessment of nature-related risks and opportunities. To reflect stakeholder perspectives, we identified representative nature-related stakeholders as survey participants⁵ and incorporated the identified material nature-related risk and opportunity factors into the survey design. Questionnaires were distributed to key nature-related stakeholders and suppliers to gather feedback, and the results were consolidated and applied in follow-up analyses, demonstrating Chunghwa Telecom's commitment to stakeholder engagement. 

Through the LEAP analysis described above, we prepared for the continued enhancement of Chunghwa Telecom's management of nature-related issues. Finally, in accordance with TNFD's four recommended disclosure pillars (Governance, Strategy, Risk and Impact Management, and Metrics and Targets) we provide related disclosures (Figure 1).

Figure 1. Chunghwa Telecom TNFD Implementation Roadmap

Scope of Chunghwa Telecom Biodiversity Assessment

Chunghwa Telecom's business footprint and value chain can be divided into three main segments: upstream suppliers, its own operational activities, and downstream consumers (Figure 2). Among these, upstream suppliers mainly include partners such as facility suppliers and engineering contractors. The Company's own operational activities are carried out through various types of sites established by Chunghwa Telecom, including base stations, telecom facilities, service centers and office buildings, pipeline facilities (cross-connect cabinets and telecommunication rooms), satellite stations, and submarine cable routes^Note.

Figure 2. Chunghwa Telecom's Business Footprint and Value Chain

Note: Base stations function to transmit signals from mobile devices to the core telecommunications network, enabling services such as voice calls and data transmission. Telecom facilities serve as large-scale information and data storage hubs, providing enterprises with access to and management of information. Office buildings and service centers are primarily used for employee work, customer reception, and the provision of telecommunications services. Cross-connect cabinets and telecommunication rooms function to connect external telecommunication cables with in-building telecommunications equipment. Satellite stations are ground-based facilities used for transmitting and receiving signals with communication satellites to enable long-distance communications. Submarine cables are fiber-optic communication systems laid on the seabed, used to connect telecommunications networks across different countries or regions.

• Own Operations

Consistent with the assessment framework from the previous year, the scope covers all terrestrial areas, including base stations, telecom facilities, pipeline facilities (including cross-connect cabinets and telecommunication rooms), satellite stations, service centers and office buildings, as well as submarine cables, in order to comprehensively assess the relationship and potential impacts between operational activities and the natural environment.

• Group Subsidiaries

This year's analysis of Group subsidiaries considered a total of 40 subsidiaries across both Taiwan and overseas locations. Based on their business operations and lines of business, the corresponding ISIC industry classifications for the Group subsidiaries were identified.

• Suppliers

This year's supplier analysis focuses on 186 key first-tier suppliers (accounting for 85.6% of procurement spending) as the subjects for analyzing nature dependencies and impact assessment. First, based on the contractual contents of the 2024 "key first-tier suppliers," and with reference to contract types and the primary nature of suppliers' business activities (wholesalers or manufacturers), the key first-tier suppliers were mapped to ISIC industry classifications, resulting in the identification of 36 industry categories.

• Customers

In conducting LEAP analysis of operations and value chains, CHT not only incorporates nature-related factors into the assessment process, but also organizes nature-related stakeholder workshops. Through internal discussions, stakeholders interacting with nature within operational activities (including customers) were identified. Questionnaires on nature-related risks and opportunities were distributed and completed to understand and incorporate their feedback and perspectives.

Figure 3. Identification Results for Major Stakeholders of Chunghwa Telecom in 2025

TNFD LEAP Analytical Approach

➤ Locate: Identifying Nature-Sensitive Operational Sites

• Own Operations

In accordance with the LEAP approach recommended by TNFD, the Company first conducted the Locate phase analysis and adopted a localized analytical process. In addition to mapping the business footprint and value chain, the Company also preliminarily identified potential dependencies and impacts on nature arising from its operational activities. Using two localized assessment criteria—Criterion I (nature sensitivity) and Criterion II (operational impact)—the ecological characteristics of areas surrounding each operational site and their potential impact levels were examined. Based on this assessment, priority levels were determined to serve as the foundation for subsequent analysis in the Evaluate phase.

Figure 4. Localized Locate Analysis Process

To evaluate the dependencies and impacts on nature of the various site types within Chunghwa Telecom's business footprint, we referenced the ENCORE^Note database and integrated globally applicable assessment scales with the characteristics of Taiwan's local natural environment. We conducted an initial screening of the dependencies and impacts on nature associated with different types of operational sites, Group subsidiaries, and key first-tier suppliers of Chunghwa Telecom. This process enabled the identification of site types with medium and high levels of nature dependency and impact, which served as the basis for selecting priority focus areas for subsequent analysis.

Note: The Exploring Natural Capital Opportunities, Risks and Exposure (ENCORE) database is a nature-related assessment database jointly developed by the United Nations Environment Programme World Conservation Monitoring Centre (UNEP-WCMC) and the Natural Capital Finance Alliance (NCFA).

The analysis of nature dependency and impacts is as follows:

Figure 5. Dependencies and Impacts on Nature by Type of Chunghwa Telecom's Operational Sites

Note: *Additional dependency items incorporated based on Taiwan's local environmental conditions and the characteristics of Chunghwa Telecom's operational site types.

Chunghwa Telecom's base stations are highly decentralized and widely distributed, with nearly 20,000 sites across Taiwan. Considering that some base stations are established to meet national infrastructure needs, mountainous area coverage, and emergency telecommunications and rescue requirements along coastal regions, their locations may be adjacent to ecologically sensitive areas, and may even fall within ecological conservation zones. Therefore, base stations remain part of this year's assessment scope, with the purpose of evaluating the boundary zones between the Company's operational footprint and the natural environment, serving as a basis for nature-related risk management measures. To demonstrate the completeness and comprehensiveness of its nature risk assessment, this year's analysis is broader than that of 2024. In addition to individual "terrestrial point-based sites"—namely operational sites (base stations, telecom facilities, satellite stations, telecommunication rooms, cross-connect cabinets, service centers, and office buildings) and value chain elements (key first-tier suppliers)—the scope of analysis has been significantly expanded to include the "group value chain" and "linear/marine sites." For the first time, key Group subsidiaries (such as Chunghwa Precision Test, Chunghwa Leading Photonics, Chunghwa System Integration, and Light Era Development) have been incorporated into a structured assessment. In 2026, Chunghwa Telecom's overall operational interface with nature is no longer limited to point-based facilities. It further incorporates "linear sites," namely submarine cable systems (New Taipei, Yilan, Taitung, and Pingtung), into the Locate and Evaluate phases. This expansion extends the Company's nature footprint assessment from terrestrial to marine boundaries, enabling a more comprehensive nature-related ecosystem risk management approach. 

We applied two localized criteria to assess the environmental sensitivity of site locations in order to determine the priority order for site evaluation. 

The two localized criteria:

In this year's Locate analysis of own operations, in addition to point-based sites such as base stations, telecom facilities, satellite stations, telecommunication rooms, cross-connect cabinets, service centers, and office buildings, the scope was also expanded to include linear sites—submarine cable systems, demonstrating Chunghwa Telecom's comprehensive management of operational sites and risk control. The results show that the proportion of first-priority concern across all site types is approximately 0% to 1.5% (Figure 6). Among them, satellite stations, telecommunication rooms, service centers, and office buildings are mostly located near urban areas with higher population density. After assessment using localized analytical criteria, none of these were classified as first-priority sites.

Figure 6. Locate Analysis Types and Results for Own Operations

• Group Subsidiaries

Considering that Chunghwa Telecom Group subsidiaries span both Taiwan and China and involve different industries, Group subsidiaries were included in the analysis scope for the first time this year and were assessed using the localized Locate analysis process (Figure 7). First, the operational activities of Group subsidiaries were inventoried and mapped to International Standard Industrial Classification (ISIC) industry categories. The ENCORE database was then used to identify ecosystem services and impact drivers associated with each industry category; at the same time, a score conversion table was used to quantify levels of dependency and impact. Using "dependency level" and "impact level" as two axes, along with "equity ownership percentage × revenue" as a quantitative scale indicator, a nature dependency and impact matrix for Group subsidiaries was developed. Based on this, Group subsidiaries with high nature dependency and impact, and high "equity ownership percentage × revenue," were selected as priority focus entities, and the location coordinates of their operational sites and facilities were further collected.
Finally, in assessing site location sensitivity, a differentiated approach was adopted in response to cross-border data availability. Sites in Taiwan were assessed using the same two localized criteria as own operations (Criterion I: nature sensitivity; Criterion II: operational impact). For sites in China, due to limitations in land-use data availability, the assessment focused on "Criterion I: nature sensitivity" only, using protected area classifications in China and globally, as well as the International Union for Conservation of Nature (IUCN) and China Red List of threatened species as reference standards, in order to support the subsequent Evaluate phase analysis.

Figure 7. The Locate Analysis Process for the Group Subsidiaries

Using the ENCORE database, ecosystem services and impact drivers associated with each industry category were identified. Dependency and impact levels were then converted into scores to construct a nature dependency and impact matrix for Group subsidiaries.

Figure 8. Matrix of Dependencies and Impacts of Group Subsidiaries

Based on the Group subsidiary dependency and impact matrix, subsidiaries with high nature dependency and impact, as well as high "equity ownership percentage × revenue," were selected as priority focus entities. This year, a total of six Group subsidiaries were identified as priority focus subsidiaries, namely Donghwa Telecom Co., Ltd., Chunghwa Precision Test Tech. Co., Ltd., Su Zhou Precision Test Tech. Ltd., Chunghwa Leading Photonics Tech Co., Ltd., Chunghwa System Integration, and Light Era Development Co., Ltd.

The following is the analysis of its nature dependency and impact:

Figure 9. Nature-related Dependencies and Impacts of Priority Group Subsidiaries

For the Locate analysis of Group subsidiaries, 40 subsidiaries were selected for screening in 2025. Based on the degree of nature dependency and impact by ISIC industry classification, and combined with the economic weighting indicator of "equity ownership percentage × revenue," a total of six priority focus subsidiaries were ultimately identified. To precisely understand the interface between their operations and nature, coordinates for 23 sites across these six priority companies were collected. In Taiwan, these include 14 offices, 3 office-and-factory buildings, 3 integrated office-and-factory sites, and 1 parking facility (21 sites in total). In China, the scope includes 1 office and 1 integrated office-and-factory site (2 sites in total).

In terms of assessment criteria, sites in Taiwan continue to follow Chunghwa Telecom's localized process and are evaluated using both "Criterion I: Nature Sensitivity" and "Criterion II: Operational Impact" for a dual assessment. For sites in China, due to data availability conditions, the assessment focuses on "Criterion I: Nature Sensitivity" to determine the sensitivity level of site locations. According to the analysis results, no sites in either Taiwan or China fall under the "first-priority" high-sensitivity category. However, in Taiwan, three sites were identified as "second-priority" (approximately 14%), while in China, one site was classified as "second-priority." These assessment results provide a scientific spatial foundation for subsequent measurement of Group subsidiaries' actual dependencies and impacts on nature.

• Suppliers

Given that suppliers are a key element of value chain management, Chunghwa Telecom continued to assess its value chain this year and conducted the Locate phase analysis in accordance with a localized approach (Figure 10). First, key first-tier suppliers were inventoried and classified into industry categories based on the International Standard Industrial Classification (ISIC), and the number of industry categories was identified. The ENCORE database was then used to analyze ecosystem services and impact drivers associated with the aforementioned industries, in order to construct a nature dependency and impact matrix. Based on this, priority industry categories were selected according to high nature dependency, high nature impact, and high total contract value. Subsequently, site location information for suppliers with medium-to-high contract values was collected, and the location sensitivity of these sites was assessed using two criteria—nature sensitivity and operational impact—as the basis for the subsequent Evaluate phase analysis.

Figure 10. Supplier Localization Analysis Process

Using the ENCORE database, ecosystem services and impact drivers associated with each industry category were analyzed. Dependency and impact levels were then converted into quantitative scores to construct a dependency and impact matrix for supplier industry categories.

Figure 11. Matrix of supplier dependency and impact by industry

Note: Only industry categories with total contract value exceeding NT$50 million in 2024 are presented. On the dependency side, the focus is on physical and ecological functional dependencies on nature; therefore, cultural ecosystem services (such as aesthetic, spiritual, or symbolic values) are not included in the dependency scoring calculation. The X-axis represents dependency level, the Y-axis represents impact level, and bubble size represents the total contract value of each industry category, with priority industry categories indicated by solid-filled bubbles.

Based on the matrix analysis results, and considering supplier industry categories in terms of nature dependency, nature impact, and total contract value, industry categories with high nature dependency, high nature impact, and high total contract value were selected as priority focus categories. This year, four priority industry categories were identified, namely public utility construction, electrical conduit and other installation engineering, industrial machinery and equipment installation, and communication equipment manufacturing.

The following is the analysis of its nature dependency and impact:

Figure 12. Dependencies and Impacts of Priority Industry Suppliers

Note: *Additional dependency items incorporated based on Taiwan's local environmental conditions and the characteristics of Chunghwa Telecom's operational site types.

Based on the four priority industry categories identified through the analysis, a total of 65 suppliers with high contract values were further selected, and the location coordinates of their sites were collected as a priority (including manufacturing facilities for manufacturers). Among these, there are 68 sites in Taiwan, comprising 62 operational addresses and 6 factory addresses. Using the same criteria applied to Chunghwa Telecom's own operations—Criterion I: Nature Sensitivity and Criterion II: Operational Impact—the sensitivity level of each site location was assessed. The results indicate that none of the sites were classified as first-priority sites.

➤ Evaluate: Nature Dependency and Impact Assessment

To comprehensively assess the dependencies and impacts on nature arising from its own operations, Group subsidiaries, and value chain, Chunghwa Telecom examined the various types of operational sites within its own operations (including base stations, telecom facilities, cross-connect cabinets and telecommunication rooms, satellite stations, service centers and office buildings, and submarine cable systems), as well as the operational activities of priority Group subsidiaries and supplier industry categories. The assessment analyzed the relationship between these activities and nature throughout each stage of their life cycle—from site selection, planning and design, construction, and operation to decommissioning—in order to identify dependencies and impacts on nature across Chunghwa Telecom's overall value chain. Based on the analysis results, the Group further established dependency and impact measurement indicators, as well as materiality assessment criteria for impacts. 

The results of this phase—including the dependency and impact items identified for various site types, Group subsidiaries, and suppliers—will serve as the basis for assessing the Group's physical risks in the Assess phase, as well as for future site management, target setting, and the promotion of sustainable supply chain management. 

Figure 13. Evaluate: the Localization Analysis Process and Its Linkages with Other Stages

• Own Operations

In the Evaluate phase, based on the nature dependencies and impacts identified through ENCORE during the Locate phase, and taking into account Taiwan's local environmental conditions, Chunghwa Telecom assessed the environmental dependencies of each site type under normal operations, as well as the potential impacts on nature arising from different stages of their operational life cycle, as detailed in the table "Dependency and Impact Items by Site Type."

Figure 14. Items of Dependencies and Impacts for Different Site Types

According to Chunghwa Telecom's various site types during normal operations, the ecosystem services on which they depend are shown in the table "Ecosystem Services Corresponding to Each Dependency Item."

Figure 15. Corresponding Ecosystem Services for Each Dependency Item

In terms of impacts, all types of operational sites generally involve land-use impacts due to the need for external access roads for facility construction and maintenance. During equipment replacement and upgrades, industrial waste is generated, and some site types may also produce small amounts of domestic waste from on-site personnel. All site types involve greenhouse gas emissions due to electricity consumption. In addition, certain wireless telecommunications facilities generate electromagnetic waves during operation; therefore, electromagnetic waves are considered an impact category for base stations and satellite stations.

Beyond point-based site assessment, the Evaluate scope is also extended to linear site types—submarine cable systems. As cross-sea linear infrastructure, submarine cables involve nature-related issues across landing stations, marine areas, coastal zones, and certain freshwater ecosystems. Based on the preliminary screening results from ENCORE, their environmental characteristics, and lifecycle activities, their dependencies and impacts on nature were identified.

Overall, submarine cable systems are highly dependent on stable natural capital and ecosystem services across different lifecycle stages—site selection, construction, operation, and decommissioning—and may also cause varying degrees of disturbance and impact across marine, freshwater, and terrestrial ecosystems.

• Site Selection Phase: Marine surveys and shore-end investigations may generate noise from vessel activity and cause short-term disturbance to marine organisms from surveying equipment. Although direct dependencies and impacts on nature are relatively limited, some submarine cable landing points are located near ecologically sensitive coastal areas, such as estuaries and coastal protection forests, which may affect the integrity and environmental sensitivity of surrounding ecosystems.
• Construction Phase: Submarine cable laying and shore-end engineering activities are highly dependent on stable marine and seabed conditions. These operations may disturb nearshore, marine, and freshwater ecosystems, including seabed disturbance, construction wastewater discharge, and noise generation.
• Operational Phase: Submarine cable systems primarily depend on stable power supply at landing stations and stable seabed conditions to maintain system operations. Direct environmental impacts during the operational phase are relatively low and mainly arise from indirect greenhouse gas emissions associated with electricity consumption at shore-end facilities, as well as localized seabed disturbance and vessel fuel combustion emissions during maintenance activities.
• Decommissioning Phase: In the future, sites may enter a decommissioning or retirement phase. Submarine cable removal and facility dismantling activities still depend on stable marine conditions and seabed conditions. Such activities may again cause seabed disturbance, noise and air pollution, and waste generation. However, through proper waste recycling, site restoration, and vegetation recovery, long-term environmental impacts may be reduced and ecological functions may be restored.

For point-based site types, based on the dependency and impact items identified in the previous phase for each type of operational site, and in reference to TNFD recommended indicator selection principles, practical considerations were applied to develop responsive, credible, and feasible dependency and impact measurement indicators through the collection of internal Chunghwa Telecom data and external publicly available data. The measurement indicators for each dependency and impact item are as follows.

Figure 16. Dependency and Impact Measurement Indicators

Note: The assessment of disaster susceptibility is based on whether a site is located directly within or within a 500-meter buffer of areas with flood susceptibility, debris flow-prone streams, large-scale landslide-prone areas, dip slopes, rock mass sliding areas, rockfall areas, soil creep areas, soil liquefaction-prone zones, active faults, tsunami inundation-prone areas, or volcanic hazard zones.

• Group Subsidiaries

In the Evaluate phase, which focuses on priority Group subsidiaries, and based on the results of the Locate analysis, no subsidiary sites were identified within the first-priority focus areas. Therefore, the assessment was shifted to a "company-level" TNFD dependency and impact questionnaire-based interview approach. Through understanding their business and value chain footprint, and with reference to the operational characteristics of different site types (such as factories, offices, construction sites, telecom facilities, etc.) across the life cycle stages of site selection, planning and design, construction, operation, and decommissioning, the relevant physical dependencies and impact items were identified.

The dependency and impact analysis results for priority Group subsidiaries will in the future be incorporated as an important reference for Group subsidiary site management, nature target setting, and nature-related risk control, thereby strengthening the foundation of the Group's sustainability governance. For more detailed information, please refer to the TNFD (Taskforce on Nature-related Financial Disclosures) report for full insights.

• Suppliers

In the Evaluate phase, the assessment focuses on priority industry categories and is further deepened based on the results of the Locate phase analysis to evaluate their dependencies and impacts on nature. By consolidating the contractual contents of suppliers with high contract values, the operational activities associated with Chunghwa Telecom are identified and summarized. These are then combined with the characteristics of suppliers' activities across different life cycle stages to systematically identify their nature-related dependency and impact items.

The analysis results of priority industry categories' dependencies and impacts on nature will serve as a reference for the Company's supply chain risk management and sustainable procurement policies. For more detailed information, please refer to the TNFD (Taskforce on Nature-related Financial Disclosures) report for full insights.

➤ Assess: Evaluation of Nature-Related Risks and Opportunities

Chunghwa Telecom and six priority Group subsidiaries, based on actual operational conditions, identified and categorized nature-related risks and opportunities through a four-step process.

Figure 17. Nature-related Risks and Opportunities Identification Process

• Nature Risk Materiality Identification

Based on the above analysis process, a total of 14 nature-related issues were identified, covering both physical risks and transition risks. A nature risk matrix (Figure 18) was developed through assessments of likelihood and impact severity. Ultimately, two physical risks with high likelihood and high impact, as well as two transition risks, were selected as material nature-related risks and opportunities and prioritized for management.

The identified physical risks are "occurrence of natural disasters" and "shortage of natural resource supply," while the transition risks include "increasing customer preference for nature-friendly products or services" and "requirements for high-efficiency, low-impact technology transition (suppliers)."

The results are presented below.

Figure 18. Chunghwa Telecom's Nature-Related Risks Matrix

After identifying the four material nature-related risks, we distributed both online and in-person questionnaires to the eight identified categories of material nature-related stakeholders to understand the extent of their daily-life linkage with nature-related risks and their expectations. This aims to ensure that, when formulating nature-related risk management strategies, the perspectives of material nature-related stakeholders are more comprehensively incorporated.

• Identification of Material Nature-Related Opportunities

To identify material nature-related opportunities for Chunghwa Telecom, 19 topics were collected and a nature-related opportunity matrix was developed. Two business performance opportunities and two sustainability performance opportunities with both high likelihood and high impact were selected as material nature-related opportunities for priority management.

The business performance opportunities include "new business models that generate positive impacts on nature or reduce negative impacts on nature" and "entry into emerging markets." The sustainability performance opportunities include "direct restoration or protection of ecosystem services or habitats" and "collaboration with stakeholders to improve ecological conditions." The relevant results are presented below.

Figure 19. Chunghwa Telecom's Nature-Related Opportunities Matrix

After identifying the four material nature-related opportunities, we also distributed both online and in-person questionnaires to the eight categories of material nature-related stakeholders. Based on the questionnaire responses, most stakeholders indicated that these material nature-related opportunities are moderately to highly relevant to their existing rights and interests and other aspects. This suggests that Chunghwa Telecom has adequately considered nature-related opportunities in its identification process and has incorporated stakeholder needs and perspectives.

➤ Prepare: Develop Strategies and Set Targets for Addressing Nature-Related Issues

Based on the results of the Assess phase, and in order to proactively reduce the impacts of nature-related risks while capturing nature-related opportunities to strengthen competitive advantage, Chunghwa Telecom's business units, in collaboration with priority Group subsidiaries, evaluate the impacts of risks and opportunities arising from nature-related dependencies and impacts on the company's business model, and develop corresponding response strategies. For detailed descriptions of strategies addressing material nature-related risks and opportunities, please refer to "Section 2: Nature-related Risk and Opportunity Response Strategies" in the Chunghwa Telecom 2025 TNFD report.  

Nature-Related Risks and Impact Management

In response to external challenges arising from intensified market competition, rapid technological advancement, increasing regulatory requirements, as well as natural environmental and climate change factors, Chunghwa Telecom continues to strengthen its risk management mechanisms to maintain stable operations and support long-term sustainable development. To this end, the Company has established the "Risk Management Committee," a functional committee under the Board of Directors, serving as the highest supervisory and decision-making body for enterprise-wide risk management. At the same time, a management-level "Risk Management Steering Committee" has been established to oversee, coordinate, and promote company-wide risk management initiatives.

Figure 20. CHT Risk Management Organization Structure

Guided by the vision of "coexistence and mutual prosperity between people and nature," Chunghwa Telecom is committed to balancing corporate growth with nature conservation and creating long-term value together with stakeholders. The Company adopts the TNFD LEAP approach framework to assess nature-related dependencies and impacts across its operational sites, business activities, and upstream and downstream value chain. Through a systematic identification and analysis of nature-related risks and opportunities arising during operational and strategic execution, the Company integrates nature risk management into its Enterprise Risk Management (ERM) system. This integration enhances risk response capabilities, reduces potential impacts, and maintains operational resilience and stability while safeguarding stakeholder interests.

In addition, to further deepen organizational understanding and management capabilities regarding nature-related issues, Chunghwa Telecom continuously promotes environmental education and sustainability-related training programs. These initiatives help employees understand the interdependencies between business activities and natural ecosystems, stay informed of international sustainability trends and nature-related initiatives, and progressively enhance employees' awareness of nature-related risks and their overall sustainability management capabilities.

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