Material Issues

Taiwan Mobile identifies and assesses material sustainability issues which relates to the environment, governance and social impacts on the organization’s business operation and its internal and external stakeholders.

  • Materiality analysis conducted/reviewed: Annually.
  • Involvement of external stakeholders in identifying the material issues: Investigate stakeholders' level of concern/degree of influence of the Company on the society via stakeholders’ online survey and held at-least one stakeholder seminar annually.
  • Materiality assessment integrated in company's ERM process: Materiality assessment prioritizes strategic goals based on impact significance, considering key factors which include operational importance, stakeholder interest, and societal impact, in alignment with risk management policies. In 2024, the results of the annual materiality assessment are systematically incorporated into the subsequent enterprise risk identification and analysis process. These outcomes are further reviewed by the Risk Management Committee to ensure that material issues are embedded in the Company’s overall risk management framework and mitigation actions.
  • The principle of Materiality assessment: we based on the double materiality to identify the internal impact on the business as well as external impact on society and the environment.
  • Materiality assessment process verification: We announces and provides the result of the materiality analysis in our 2024 ESG report, and had been completed assurance by the third-party, KPMG via "GRI Standards" in May 2025, so that the process of the materiality analysis had been included as well. The Assurance Statement please refer to http://english.taiwanmobile.com/english/esg/SustainabilityReportingBoundariesandAssurance.html
  • Materiality assessment results signed off: In 2024, the 23 sustainability issues were discussed by the ways of online surveys, stakeholder seminar and ESG working group, the ESG steering committee and finally approved by the board of directors.
Materiality analysis process

Based on the three-step identification process, 23 sustainability issues have been summarized in 2024. We conduct and review our materiality analysis at least annually to ensure our material issues align with the global and local trends.

The results of the materiality analysis have been incorporated into the company's Enterprise Risk Management (ERM) process as a key reference. The Risk Management Committee is subsequently responsible for monitoring and strictly controlling risk management-related issues to ensure continuous improvement. In 2024, 19 risks were identified, with 6 of these being included in TWM's Top 6 material issues for the year.

The materiality analysis process is included annually in the sustainability report's assurance scope and has obtained an Independent Limited Assurance Report to ensure the completeness and accuracy of the process.

Step 1: Research on Global Trends and Sustainability Topics in the Telecom Sector

Taking into account Taiwan Mobile’s operations, business relationships, ESG goals, and the interests of its eight major stakeholder groups, the Company compiled a comprehensive list of sustainability topics by referring to international frameworks such as the Sustainability Accounting Standards Board (SASB), Global Reporting Initiative (GRI) Standards, S&P Dow Jones Sustainability Indices (DJSI), World Economic Forum (WEF) Global Risks Report, and sustainability trends and issues in the ICT industry both in Taiwan and abroad.

Step 2: Survey of Senior Management and External Stakeholders

A questionnaire was designed and distributed to members of the ESG Working Group (CXO-level) to assess the financial materiality (positive/negative) and impact significance of each sustainability topic.

In 2024, a dedicated materiality survey was conducted for the eight major stakeholder groups. Using statistical sampling methodology, a total of 632 valid responses were collected, allowing the Company to capture a broad and diverse range of stakeholder perspectives.

According to the survey results, the top six Material Issues identified by stakeholders were: anti-fraud (positive), privacy protection (positive), information security (positive), emergency response to social crises (negative), digital inclusion and social innovation (positive), and corporate governance and ethical business conduct (negative).
Details of these findings were presented during the 2024 stakeholder dialogue sessions.

Step 3: Double Materiality Matrix Analysis and Outcome

Stakeholder insights gathered in Step 2 were plotted based on the principle of double materiality:

  • X-axis: Financial Materiality (level of financial impact on Taiwan Mobile)
  • Y-axis: Impact Materiality (considering scale and scope of impact, ability to remediate, likelihood of occurrence, and stakeholder concern)

The analysis also incorporated factors such as actual or potential impact, and timing of occurrence (short-, medium-, or long-term). The result was a set of Taiwan Mobile’s Material Issues plotted in both Positive and Negative Impact Matrices.

Axis Factors Considered Assessment Method
Axis x Financial materiality
  • Financial impact (comprehensive assessment of the impact on the impact subject)
Axis y Impact materiality
  • Impact degree (comprehensive assessment of scale, scope, disastrousness)
  • Possibility of occurrence (comprehensive assessment of probability, speed or frequency of occurrence)
  • Degree of stakeholder attention (evaluate the degree of influence of external stakeholders on the decision-making of this issue)
Materiality Analysis

In 2024, ten members of the ESG Working Group identified 23 key sustainability topics. These topics were further refined by incorporating feedback from both internal and external stakeholders, including the ESG Working Group and 632 valid stakeholder questionnaires, based on the principle of dual materiality, evaluating each topic's "impact on TWM's own operations and finances" and "impact on society and the environment", and ranking the positive and negative dual materiality matrix; the first six key themes are as follows in order:

  • Operational performance (positive impact)
  • Talent development and retention (negative impact)
  • Privacy protection (positive impact)
  • Corporate governance and ethical business operation(positive impact)
  • Climate change mitigation and adaptation (negative impact)
  • Green applications and operations (negative impact)
TWM’s Dual Materiality Matrix (positive)
TWM’s Dual Materiality Matrix (negative)
Material Issues for Enterprise Value Creation
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  Material Issue 1 Material Issue 2 Material Issue 3
Material Risk or Opportunity impacting company’s business Climate Change Mitigation and Adaptation Talent development and retention Privacy Protection
Business Case material to company’s business Approximately 98% of our GHG emissions come from electricity consumption, which is essential to maintain continuous network operations across our widespread base station infrastructure. Climate change has significantly increased the frequency and severity of extreme rainfall events, especially in subtropical regions like Taiwan. For Taiwan Mobile, this represents a critical operational risk. As a result, extreme rainfall poses the most significant physical climate risk to our business, leading to potential damage to telecom infrastructure, unstable power and water supplies, and service disruptions. These events also generate unplanned maintenance costs and recovery expenses, negatively impacting our operational continuity and customer experience. Given this exposure, Taiwan Mobile considers climate-induced physical risks a material issue that must be proactively addressed through strategic investment, scenario planning, and resilience enhancement.   Taiwan Mobile firmly believes that talent is our most valuable intangible asset and a key driver of long-term competitiveness. However, in the context of global trends such as declining birth rates and an aging population, attracting and retaining skilled talent has become increasingly challenging.
In Taiwan, this trend is further exacerbated by the particularly low birth rate, making talent competition in the local labor market even more intense.
This demographic shift presents a significant human capital risk, where shortages in workforce capacity or skillsets could impede strategic growth, delay innovation, and increase operational costs. Without proactive investment in employee development, companies risk higher attrition, weakened morale, and increased expenditures on recruitment and training.
In particular, career development has emerged as a key factor influencing employees’ decisions to stay. Failure to provide structured upskilling and advancement opportunities could lead to disengagement and loss of critical talent. Conversely, creating an environment that supports long-term career growth can reduce turnover risks and sustain organizational resilience in a highly competitive labor market.
.		 As digital services proliferate—especially in areas such as mobile payments, cloud computing, and AI-driven applications—data privacy has evolved from a compliance necessity to a competitive differentiator. For Taiwan Mobile, safeguarding customer data is not only foundational to maintaining our license to operate, but also essential for building trust and expanding in high-growth digital markets.
To address this, Taiwan Mobile has established a comprehensive privacy governance framework, underpinned by dual ISO certifications (ISO 27001 for Information Security and ISO 27701 for Privacy Information Management). Our Cyber Security and Data Privacy Protection Committee, chaired by the President and overseen by independent directors, ensures Board-level accountability and cross-functional integration. Key privacy controls are embedded across our business operations, supported by 24/7 cyber monitoring and a “Privacy by Design” approach in product development.
Recognizing privacy protection as a strategic opportunity, Taiwan Mobile has actively leveraged its strong cybersecurity infrastructure to develop a suite of privacy-enhancing services. These include the OP Scam Buster – Enterprise Edition, OP Scam Buster – Personal Edition, and the Number Masking Service, which empower customers to protect their personal information and reduce exposure to scams. These services not only mitigate individual risk but also strengthen our brand as a trustworthy digital service provider.
By transforming privacy protection into an integrated service offering, Taiwan Mobile creates new revenue streams and customer value, while reinforcing its leadership in digital trust and responsible innovation.
Business Impact Risk Risk Opportunity
Business strategies To address climate-related risks and transition toward net-zero emissions by 2050, Taiwan Mobile has implemented an integrated mitigation and adaptation strategy. This strategy is overseen by the ESG Steering Committee and operationalized through the Environmental Working Group, with oversight aligned to our Enterprise Risk Management (ERM) framework and TCFD guidance.
On the mitigation front, we have set group-wide science-based targets, including both annual and long-term carbon reduction goals, and a corporate-wide renewable energy adoption roadmap. We actively invest in energy-saving and low-carbon technologies, such as adopting high-efficiency equipment, deploying AI-powered optimization systems, purchasing green electricity, and planning on-site solar PV installations.
On the adaptation side, we focus on enhancing the resilience of our telecom infrastructure against extreme weather events. Base stations and telecommunications rooms are equipped with backup batteries, high-weather-resistance power modules, and emergency generators. We continue to expand network coverage in disaster-prone areas while ensuring these sites have sufficient power and mobility resilience, including water storage tanks (with 48-hour capacity), mobile relief vehicles, and climate risk insurance coverage for telecom equipment. Furthermore, we have updated our extreme weather SOPs to strengthen emergency preparedness.
These strategies are aligned with our long-term vision—2035 Zetta Connected 2.0—and support our transition to a low-carbon, climate-resilient business model while maintaining uninterrupted service for our customers.		 This approach aligns with our long-term vision of 2035 Zetta Connected 2.0, which emphasizes human capital as a foundation of sustainable innovation and growth. To address workforce-related risks and support long-term organizational resilience, Taiwan Mobile has established a comprehensive talent development strategy centered on learning, engagement, and internal mobility:
  • The company creates a diverse and enriching learning environment by conducting annual employee training needs assessments and quarterly consultations with business group managers to align learning programs with strategic goals.
  • Employees are supported through Individual Development Plans (IDPs) and a wide range of interdisciplinary learning opportunities. All training activities and outcomes are tracked quarterly to ensure progress and alignment with development objectives.
  • Taiwan Mobile promotes open and transparent communication through monthly cross-level communication forums, annual employee opinion surveys, and monthly all-hands meetings that include a dedicated employee Q&A section. Feedback collected is analyzed and used to formulate and track improvement plans on a quarterly basis.
  • The company’s signature “Supermen Program” is designed to accelerate the growth of high-potential employees through rotational assignments and mentorship.
  • The company’s signature “Supermen Program” is a large-scale talent development initiative designed to lead employees across the organization in upskilling and reskilling, focusing on Robotic Process Automation (RPA) and related AI capabilities.
  • These efforts are supported by internal job posting systems and engagement tools to foster career advancement and retention.
This strategy strengthens Taiwan Mobile’s ability to maintain a motivated, capable workforce and mitigate talent attrition risks in a rapidly changing labor market. 		To manage the growing risks and unlock the opportunities associated with data privacy in a digital-first environment, Taiwan Mobile has implemented a comprehensive, multi-layered strategy focused on governance, prevention, and innovation:
  • A dedicated privacy governance framework is in place, led by an independent Chief Information Security Officer (CISO) and overseen by the Cyber Security and Data Privacy Protection Committee, which reports directly to the Board of Directors.
  • Taiwan Mobile has obtained ISO/IEC 27701 and ISO/IEC 27001 certifications, and undergoes biannual internal and external audits to assess the effectiveness of privacy and information security controls. The Company also operates a Personal Information Protection Management System (PIPMS) to institutionalize risk identification, assessment, and mitigation across the organization.
  • We adopt a “Privacy by Design” approach throughout product and service development—particularly for AI, fintech, and digital applications—ensuring privacy considerations are embedded from the outset.
  • A 24/7 cybersecurity monitoring center is in place to detect and respond to potential threats in real time, supported by automated incident detection and response mechanisms.
  • All employees and third-party contractors receive regular privacy protection and social engineering training, reinforcing a culture of awareness and accountability.
  • Public transparency is promoted through disclosure of key privacy performance indicators, such as the number of incidents identified and resolved.
Beyond internal governance, Taiwan Mobile recognizes data privacy protection as a strategic business opportunity. Leveraging our strong cybersecurity infrastructure, we have developed and launched a portfolio of privacy-enhancing services, including:
  • OP Scam Buster – Enterprise Edition, which enables corporate clients to identify and block malicious domains and spoofed websites targeting their brands.
  • OP Scam Buster – Personal Edition, a consumer-facing app that scans messages and domains to detect and prevent fraud, with over 300,000 downloads to date.
  • Number Masking Service, which anonymizes phone numbers during customer interactions to prevent leakage of sensitive data.
These services not only help prevent personal data breaches and reduce fraud risk for users, but also generate new revenue streams and reinforce customer trust in TWM’s digital ecosystem. By transforming privacy protection into a productized capability, Taiwan Mobile is turning regulatory compliance into competitive advantage.
Target /Metric Taiwan Mobile has set a clear decarbonization pathway aligned with international frameworks such as SBTi, RE100, TCFD, and TNFD. Our near- and long-term emission reduction targets encompass both direct and indirect emissions, with regular performance tracking and public disclosure. Oversight of environmental and climate-related strategies is provided by the Environmental Working Group, which coordinates cross-functional actions and reports to the ESG Steering Committee. In parallel, we have established resilience targets to mitigate physical climate risks and ensure operational continuity.
Targets and Metrics:
  • Achieve net-zero GHG emissions across Scope 1, 2, and 3 by 2050
  • Reduce Scope 1 and 2 emissions by:
    • 42% by 2030 (base year: 2022)
    • 66% by 2035 (base year: 2022)
  • Reduce Scope 3 emissions by:
    • 25% by 2030 (base year: 2020)
    • 40% by 2035 (base year: 2020)
  • Implement RE100 roadmap to increase the share of renewable electricity:
    • 35% by 2030
    • 60% by 2035
  • Achieved 100% resilient infrastructure coverage for all core server rooms, including backup power systems, weather-resistant modules, emergency response SOPs, and climate risk insurance.
To retain talent and mitigate the risks associated with an aging population and declining birth rate, Taiwan Mobile continuously monitors employee engagement and turnover trends, and implements talent development initiatives with quantifiable targets and metrics.
Targets and Metrics by 2035:
  • Average training hours per employee: Achieve at least 50 hours annually through diverse and flexible learning channels.
  • Employee recognition score: Reach 74% of employees feeling their dedication is acknowledged.
  • Satisfaction with employee support programs: Achieve an internal score of 95 out of 100 on multi-dimensional employee assistance offerings (e.g., physical, psychological, and career support services).
  • Supermen Program： 100%Employee Training Participation Rate, 80%Practical Application Rate
Recognizing data privacy as a fundamental pillar of digital trust, Taiwan Mobile integrates privacy risk controls into its business operations through ISO-certified systems, real-time monitoring, and robust governance. The Cyber Security and Data Privacy Protection Committee, led by a dedicated Chief Information Security Officer (CISO) and including independent director participation, oversees company-wide privacy and cybersecurity strategies. Cross-functional working teams execute operations and report regularly to the Board.
Key performance indicators are designed to track effectiveness in data protection, breach prevention, and employee awareness.
To ensure robust privacy protection and unlock long-term business opportunities in data security, Taiwan Mobile has set the following targets and metrics, with both annual performance benchmarks and long-term strategic goals aligned with the 2035 Zetta Connected 2.0 vision.
Long-term Targets (by 2035):
  • Maintain zero confirmed personal data breach incidents caused by hacking or intrusion.
  • Achieve zero successful cyberattacks through social engineering techniques (e.g., phishing emails).
  • Reach 650,000 cumulative registered users for the OP Scam Buster – Personal Edition app, strengthening fraud prevention and customer privacy protection.
Annual Management Indicators:
  • Maintain zero confirmed personal data breach incidents involving customer information.
  • Maintain ISO/IEC 27001 and ISO/IEC 27701 certifications through successful completion of biannual internal and external audits.
  • Achieve 100% blocking rate of outbound sensitive data transmissions, such as unauthorized email attachments or external uploads
    ▸ e.g., 181 cases automatically blocked in 2024.
  • Ensure 100% completion rate for annual privacy and security training for all employees and third-party contractors.
  • Maintain a fully staffed Data Protection team, with oversight by the CISO and regular reporting to the Board.
These targets and KPIs are designed to support both regulatory compliance and product innovation, ensuring trust in Taiwan Mobile’s digital ecosystem while leveraging data privacy as a competitive differentiator.
Target Year 2035 2035 2035
Progress The Environmental Management Working Group holds biannual meetings to track environmental performance, identify areas for improvement, and coordinate company-wide action. In 2024, the progress on climate-related targets is as follows:
  • Scope 1 and 2 emissions increased by 20.6% compared to the 2022 baseline. This was primarily due to the increased electricity consumption from 5G expansion and the merger with T-Star at the end of 2023. Taiwan Mobile will reset its emission reduction targets using 2024 as the new baseline.
  • Achieved a 16.3% reduction in Scope 3 emissions in 2024, exceeding the 2035 target of a 10.0% reduction from 2020 baseline.
  • Achieved a 16.3% reduction in Scope 3 emissions in 2024, exceeding the 2035 target of a 10.0% reduction from 2020 baseline.
  • Renewable electricity accounted for 10.2% of total electricity consumption in 2024, exceeding the original target of 8%.
  • 100% of core server rooms have achieved resilient infrastructure standards, including completion of backup power systems and weather-proof upgrades.
In 2024, Taiwan Mobile made significant progress in advancing its talent development and retention strategy, as reflected in the following key performance results:
  • Average training hours per employee reached 65.9 hours, surpassing the long-term target through the continued expansion of diverse and flexible learning channels.
  • Employee recognition score reached 84%, indicating a high level of perceived acknowledgment for employee contributions.
  • Satisfaction with employee support programs achieved an internal score of 96.2 out of 100, reflecting the effectiveness of the company’s multi-dimensional assistance offerings across physical, psychological, and career-related dimensions.
  • The “Supermen Program,” launched in 2025, originally aimed for 30% of participants to apply their learning in daily work by the end of the year; however, by the end of July, this figure had already surpassed 50%.
In 2024, Taiwan Mobile continued to strengthen its privacy protection practices and achieved the following outcomes:
  • Zero confirmed personal data breach incidents involving customer information, maintaining a clean record of data security.
  • Successfully maintained ISO/IEC 27001 and 27701 certifications, passing both internal and external audits conducted semiannually.
  • Achieved a 100% blocking rate for unauthorized outbound transmission of sensitive data, with 181 attempted cases automatically intercepted by the data loss prevention (DLP) system.
  • Reached a 100% completion rate for annual privacy and cybersecurity training, covering all employees and third-party contractors.
  • Maintained a fully staffed Data Protection team, operating under CISO-led oversight with regular reporting to the Board and active engagement from the Cyber Security and Data Privacy Protection Committee.
Executive Compensation Climate-related KPIs are integrated into the ESG performance indicators of senior management. These include key metrics such as carbon emissions reduction, renewable energy usage, and the implementation of resilient infrastructure across core server rooms.
In 2024, ESG performance—specifically Talent development and retention-related performance—was linked to 30% of senior executives’ variable compensation. 		The employee training hours and employee engagement targets are integrated into the ESG performance indicators of senior management.
In 2024, ESG performance—specifically Talent development and retention-related performance—was linked to 30% of senior executives’ variable compensation.
Recognizing the materiality of Talent development and retention -related issues to the company, starting from 2025, the achievement of ESG KPIs will be fully (100%) linked to the variable compensation of senior management. 		Privacy-related KPIs are integrated into the ESG performance indicators of senior management. These include key metrics such as the prevention of personal data breaches, maintenance of ISO/IEC 27001 and 27701 certifications, 100% completion rate of employee privacy training, effectiveness in blocking unauthorized data transmissions , and user adoption of related products and services, such as the OP Scam Buster – Personal Edition.
In 2024, ESG performance—specifically data privacy and cybersecurity performance—was linked to 30% of senior executives’ variable compensation.
Recognizing the materiality of privacy protection to the company’s long-term trust and operational integrity, starting from 2025, the achievement of ESG KPIs will be fully (100%) linked to the variable compensation of senior management.
Material Issues for External Stakeholders
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  Impact 1 Impact 2
Material Issue for External Stakeholders Climate Change Mitigation and Adaptation Privacy protection
Cause of the external impact and the
coverage of the business activity that has been considered in the assessment.		 Products and services, which is cover over 50% of the business actitvity. Products and services, which is cover over 50% of the business actitvity.
External stakeholder(s)/impact area(s) evaluation Environment & Consumers/end -users & External employees. Both combined in positive and negative impacts. Society & Consumers/end -users. Both combined in positive and negative impacts.
Topic relevance on external stakeholders Taiwan Mobile has made concrete commitments to achieving net-zero emissions by 2050 and actively adopts energy-efficient equipment, develops green products and services to support the low-carbon transformation of the telecommunications industry. These efforts allow consumers to access services that are both environmentally friendly and of high quality.
In addition, TWM's climate adaptation strategies—such as building disaster-resilient base stations and achieving 100% resilient infrastructure coverage for core server rooms—ensure service continuity during extreme climate events, safeguarding consumers’ communication needs.
From a broader value chain perspective, TWM engages its suppliers in GHG inventory and low-carbon initiatives, thereby extending environmental influence and encouraging sustainable practices across the industry.
However, global warming and intensified typhoons continue to pose significant physical risks. Outdoor telecom infrastructure is increasingly vulnerable to damage, which could result in service disruptions, negatively affecting consumer experience and TWM’s market competitiveness. 		As digital services such as mobile payments, cloud computing, and AI applications continue to expand, data privacy has become a critical concern for consumers and society at large. People increasingly rely on digital infrastructure to manage their daily lives, which elevates the expectations for data protection and transparency across all industries, especially telecommunications.
On the positive side, Taiwan Mobile leverages its robust privacy governance and cybersecurity infrastructure to offer services that enhance personal data protection for users. These include the OP Scam Buster – Personal Edition, OP Scam Buster – Enterprise Edition, and the Number Masking Service, which collectively reduce fraud risks and improve user confidence in digital services. These innovations not only help individuals avoid financial and emotional harm from scams but also support societal resilience in the face of increasingly sophisticated cyber threats.
On the negative side, a single data breach can significantly erode public trust, cause reputational and regulatory harm, and undermine Taiwan Mobile's license to operate. As a telecommunications provider managing vast amounts of sensitive personal data, TWM faces growing risks from social engineering attacks, phishing, and other malicious threats. To address these risks, TWM has implemented a company-wide Personal Information Protection Management System (PIPMS), achieved ISO/IEC 27001 and 27701 certifications, and operates a 24/7 cybersecurity monitoring center—all of which work together to prevent privacy violations and ensure stable, secure services.
Output Metric
  • 346,767.47 tCO₂e – Total Scope 1 and 2 emissions in 2024, 356,189.49 tCO₂e in Scope 3
  • 3,550 tCO₂e – Estimated GHG emissions avoided via digital services in 2024 (e.g., e-billing, paperless services, digital meetings)
  • Number of confirmed personal data breach incidents involving customer information: 0
  • Number of outbound sensitive data transmissions automatically blocked: 181 cases in 2024
  • Number of users protected by OP Scam Buster – Personal Edition: Over 300,000 accumulated downloads.
  • Number of fraudulent or scam websites intercepted and blocked by OP Scam Buster – Enterprise Edition: Over 130 million domain detections, 80,000+ malicious websites identified and reported.
  • Number Masking Service:
      – Cumulative number of calls securely routed to protect personal data: 28.76 million (as of end-2024)
      – Estimated number of personal data exposures prevented: Over 300 million user instances
      – Total number of corporate clients utilizing the service: Over 15,000 companies
Impact Valuation Environmental value lost/ gained Access to product/service with positive impact provided
Impact Metric NTD -1,010,224,000 NTD 922,070,000