Risk Management

Risk Management Policy and Process

Taiwan Mobile Co. (TWM) established a risk management policy in 2011, and relevant policies and procedures were disclosed on the official website. The policy was revised for the fifth time by the Board of Directors in 2025 as the highest guiding principle for risk management. The Company actively plans risk management policies, the organizational structure and risk management systems; potential risks in the operation of the Company are dealt with on a preventive basis before they occur.

The Risk Management Committee was established in 2015 with the approval of the Board of Directors. In November 2025, to enhance the level of risk management governance, the Risk Management Committee was incorporated into the Audit and Risk Management Committee, a functional committee under the Board of Directors, with a Risk Management Steering Committee established under it to strengthen the Company's risk management mechanism. The Audit and Risk Management Committee assists the Board of Directors in overseeing and reviewing the operation and implementation of risk management. The Risk Management Steering Committee is responsible for coordinating risk-related matters and implementing risk management decisions, and reports on its operations to the Audit and Risk Management Committee and the Board of Directors at least once a year to ensure that relevant risk issues are effectively managed.

The Internal Audit Office conducts an annual review of the risk management mechanism and annual year-end risk assessments, and rates the importance and possibility of each risk, then calculates the risk value according to the results of the rating. The risk value becomes the basis for the following year's audit plan.

In 2025, the audit results did not show any internal control deficiencies and abnormalities. Nevertheless, 59 concrete suggestions for improving operational procedures were proposed as ways to improve the quality of management. The improvements and suggestions are to be tracked on a quarterly basis until they have been completed.

Risk Management Scope

TWM integrates and manages various important risks that may affect operations and profits by proactive and cost-effective manner along with a response mechanism from the three-level risk management.

The company's important risks include "Operating risk", "Risks related to information privacy and security", "Innovation risk"... and so on. Please read the detail content in the company's annual report.

Risk Management Structure
*NoteThe Board of Directors exercises control over the ESG Steering Committee and the Cyber Security and Data Privacy Protection Committee. The Audit and Risk Management Committee is a functional committee under the Board of Directors, with the Risk Management Steering Committee established under it. If any major event or incident happens, the responsible unit shall report it to the Operations and Management Committee and corresponding Committee or Working Group to undertake any necessary measures.
Risk Operation

TWM has established the Audit and Risk Management Committee, which consists of all independent directors of the Company and is chaired by one of the independent directors. A Risk Management Steering Committee is established under the Audit and Risk Management Committee to supervise and strictly control risk management-related issues and continuously promote a risk management-oriented management model to achieve continuous improvement.

The Risk Management Steering Committee meets at least once every six months and regularly communicates and discusses risk management-related issues with various committees and working groups, including the Operations and Management Committee, Occupational Safety and Health Committee, Communication Quality Assurance Committee, Cyber Security and Data Privacy Protection Committee, ESG Steering Committee, Environmental Working Group, and Innovation Working Group, to effectively identify risk issues across different areas.

In the event of a major event or proposal, each responsible unit shall report it to a meeting of operation management or each management committee to decide the necessary measures. Each functional committee not only proactively focus and identify the potential risk issues within internal and external for the company, but bring up appropriate solutions.

The company has proactively promoted the mechanism of risk management since 2011.
The followings are the status of main operating over the years.

  • Formulated Risk Management Policy in 2011.
  • The Risk Management Committee was established in 2015.
  • Revised the Risk Management Policy in 2017.
  • The Risk Management Policy was revised the second time in 2020.
  • The Chief Internal Auditor attended the Board of Directors to report the business of the Risk Management Committee on August 5, 2021.
  • The Risk Management Committee meeting was convened for second time to discuss 17 issues in 2021.
  • Revised the Risk Management Policy for third time and approved by the Board of Directors in2022.
  • The Chief Internal Auditor attended the Board of Directors to report the business of the Risk Management Committee on August 1st , 2022.
  • The Risk Management Committee meeting was convened for second time to discuss 19 issues in 2022.
  • The Chief Internal Auditor attended the Board of Directors to report the business of the Risk Management Committee on August 4 , 2023.
  • The Risk Management Committee meeting was convened for second time to discuss 17 issues in 2023.
  • The Chief Internal Auditor attended the Board of Directors to report the business of the Risk Management Committee on August 5 , 2024.
  • In 2025, the Risk Management Committee convened meetings in May and November, with a total of 12 agenda items. Various committees and working groups reported on risk-related issues, including the identified risks and corresponding risk treatment measures. The operations of the Risk Management Committee were reported to the Board of Directors on August 7, 2025.

In 2025, the Risk Management Committee convened meetings in May and November to discuss a total of 12 agenda items on risk-related issues and corresponding mitigation measures proposed by various committees and working groups. The Committee reported its operations to the Board of Directors on August 7, 2025. In November 2025, to enhance risk management governance, the Risk Management Committee was incorporated into the Audit and Risk Management Committee, with the Risk Management Steering Committee established under it.


Risk Management Procedure

The Risk Management Steering Committee and ESG working group reviews global, local, industrial trends, and identifies relevant risks that are applicable to TWM on a corporate level, discuss the risk prioritization according to the impact levels and the possibility of occurrence.

Annually, an inventory is conducted based on the risk categories and risk items, and each risk item is further reviewed to adjust the risk description based on emerging international trends. After evaluating potential impacts, each responsible unit shall select priorities according to risk levels and adopt corresponding measures and actions to control risks under acceptable range, and corresponding measures and risk tolerance indicators shall be formulated.
Risk Management Policy

Risk tolerance indicators, thresholds of overall gap between target/metric and actual performance that the company is accepting to tolerate, are established and monitored for each risk item. Taking "Changes in customer behavior" and " Sustainable and Responsible Supply Chain Management " as examples:

  • **Changes in customer behavior:**We Set the proportion of "Double-Play" plan covers 80% of our existing own households client as Risk tolerance Indicators
  • Sustainable and Responsible Supply Chain Management:
    1. Due diligence coverage of at least 90% of major Tier 1 suppliers.
    2. Zero major supply chain disruptions.
    3. Overall supply chain carbon emissions reduction of at least 9%.

Risk Management Matrix

Analysis of Emerging Risks and Opportunities

△ Emerging Risk:defined as an emerging and external risk that is expected to have a significantly long-term impact on the company's business.

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Risk Emerging Risk correlate with WEF category TWM Material Topics Description Impact Mitigating actions Risk Tolerance

Information privacy and person data protection

Technological Privacy protection
  • Domestic and international personal data privacy regulations are becoming increasingly stringent, along with heightened public awareness of personal data protection.
  • Data breaches involving personal information from emerging services and products may lead to diminished user rights, reduced company revenue, and damage to corporate reputation.
  • To establish a Personal Data Protection Commission and ensure the protection of information privacy rights, as well as to promote the rational use of personal data, the Executive Yuan has set up a Preparatory Office for the Commission to strengthen oversight related to information privacy and security. Our company must continuously invest resources to establish a comprehensive personal data privacy management system, in order to meet the external risks associated with compliance with relevant laws and regulations and user expectations.
  • To provide a wide range of high-quality telecommunications and value-added services, the scope of our innovative services and products will continue to expand over the next three to five years. This will involve the processing of a large volume of personal data and privacy matters. In the event of an accidental personal data breach affecting users' privacy, the company would be legally liable. For example, compensation to affected users must be paid at not less than NTD500 and up to NTD20,000 per person per incident, and in serious cases, an administrative can fine between NTD150,000 and NTD15,000,000. In addition to compensation to users, the company may also face impacts such as user attrition and decreased revenue.
  • To address external impacts relating to information privacy and information security, our company has established mechanisms for the protection of users' personal data privacy, staying international trends and regulatory requirements. In alignment with the development of innovative services and products, we continuously optimize operational processes involving personal data privacy.
  • By engaging impartial third-party assessments to verify the effectiveness of our personal data privacy management, we ensure the continued validity of certificates such as ISO 27001 and ISO 27701 (Information Security and Personal Information Management Systems), as well as BS 10012 and ISO/IEC 29100 (Privacy Framework). These standards are integrated into our business operations, driving ongoing enhancements to our security mechanisms. We are planning the following actions to further elevate our information privacy and security standards:
  1. Establishing and regularly updating information security policies and standards.
  2. Strengthening the functions of the dedicated information security organization.
  3. Continuously conducting personal data security audits and data breach simulating drills.
  • Legal Disputes and Customer Complaint Controversies

Cyber Security and Cyber Attack

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Technological Information security
  • Cyberattack methods are rapidly evolving with the application of AI and other advanced technologies, and the scope of attacks is expanding to include both enterprises and their supply chains.
  • Regulatory authorities are strengthening information security management for publicly listed companies and imposing increasingly stringent network security protection requirements specifically for the telecommunications industry.
  • Amid the emergence of various new cyberattacks across industries worldwide, it is anticipated that, over the next three to five years, hackers will strengthen their attack techniques by leveraging tools such as AI. The company may be impacted by these emerging cyber threats, such as ransomware attacks that encrypt corporate files, or social engineering attacks that result in the leakage of sensitive information. For example, if the company suffers a DDoS attack causing a one-day service outage, the estimated revenue loss would be approximately 546 million NTD.
  • As a telecommunications critical infrastructure provider designated by the Executive Yuan—and one of Taiwan's three major telecom operators—any inability to withstand external cyberattacks could severely disrupt user telecommunications services. This, in turn, may lead to compensation for service interruptions, revenue reduction, and reputational damage. Regulatory authorities have mandated the strengthening and implementation of information security maintenance programs, which means the company will need to continuously increase its investment in defensive measures to mitigate external risks associated with cyberattacks and regulatory compliance requirements.
  • To address external impacts related to cybersecurity, our company must continuously invest resources to establish information and communications security protection mechanisms and promote security measures in order to comply with the regulatory authorities' cybersecurity management requirements. We will review the effectiveness of these protection mechanisms and the achievement of security objectives, and report progress and benefits to the Information Security and Personal Data Privacy Committee.

The cybersecurity protection mechanisms include:

  1. Engaging external auditors to inspect and ensure compliance with regulatory requirements, such as the Mobile Broadband Cybersecurity Management directives from the Ministry of Digital Affairs.
  2. Conducting penetration testing that simulates hacker behavior to identify and remediate vulnerabilities.
  3. Establishing various quantitative indicators to track the security posture.
  4. Enhancing the cybersecurity threat detection and management mechanism (Security Operations Center, SOC) and conducting red team exercises.
  5. Monitoring and analyzing information security protection systems and equipment, and evaluating the implementation of a Zero Trust Architecture (ZTA) framework.
  • Information Security Incidents Handling

Geopolitical and Economic/Political Changes

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Geopolitical Supply chain management
  • Geopolitical Conflicts: Escalating regional conflicts and international tensions could disrupt cross-border logistics and supply chains.
  • Trade and Technology Controls:The scope of global technology controls continues to expand amid growing emphasis on technology sovereignty and supply chain autonomy. Tariffs, export controls, and economic sanctions increase the risk of sourcing critical equipment and components and create greater uncertainty regarding their future supply.
  • Supply Chain Concentration: Concentration of supply sources in specific countries or regions may increase the risk of supply disruptions and cost fluctuations.

Increased geopolitical volatility, coupled with greater difficulty in controlling external factors, could lead to the following operational impacts on Taiwan Mobile:

  • Supply Side: Delays or shortages of telecommunications equipment, consumer electronics, and key components are possible. Certain equipment may also be difficult to replace in the short term.
  • Cost Side: Tariffs, transportation, and procurement costs may rise.
  • Operational Side: Obstacles to equipment acquisition could affect network construction, maintenance, and product sales. Over the longer term, they may also affect supplier strategies and capital expenditure planning.
  • Risk Monitoring: Continuously monitor changes in international political and economic policies, trade policies, and supply chains.
  • Risk Assessment: Incorporate country-, industry-, and product-specific risks into supplier management.
  • Supply Resilience: Strengthen management of delivery times, supply sources, and alternative solutions for high-risk suppliers and product items.
  • Due diligence review coverage of at least 90% of major Tier 1 suppliers.
  • Zero major supply chain disruptions.

Responsiveness to the trend of innovation and creativity energy

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Technology innovation & application
  • The rapid evolution of cutting-edge technologies such as AI, 5G, cloud computing, AIoT, and smart energy continues to reshape industry competition and business models. Failure to promptly grasp technological and market trends and transform existing core capabilities such as networks, data, users, and channels into innovative services with market value and scalable potential may result in missed opportunities in emerging markets and growth. Furthermore, if investments in cutting-edge technologies fail to effectively connect with market demand, business models, and the company's core capabilities, uncertainties in resource allocation and investment returns may arise. As AI is gradually scaled up and implemented in operational and service scenarios, emerging risks such as data governance, information security, privacy, AI ethics, and legal compliance must also be considered.
  • Rapid changes in technology and the market may accelerate the iteration of existing products, services and business models. If the pace of innovation or commercialization is slower than the market, it may affect new growth momentum and competitive advantage. If investments in new technologies and AI infrastructure fail to achieve economies of scale, it may affect resource allocation and return on investment. If AI applications do not properly manage data, cybersecurity, ethical and legal compliance risks, it may also affect operational resilience, customer trust and corporate reputation.
  • TWM continues to leverage our multi-tiered growth strategy of Telco, Telco+, and Telco+Tech to seize opportunities in AI and cutting-edge technology development. We will combine our core capabilities—including millions of users, networks, data, and distribution channels—to develop differentiated and scalable products and services. We will strengthen our market orientation and investment discipline, dynamically reviewing technology maturity, market demand, and investment returns through PoC, MVP, and phased commercial validation mechanisms. We will deepen our AI infrastructure, models, applications, and governance capabilities, while ensuring data security, privacy, ethics, transparency, and legal compliance. We will integrate CT, IT, OT, AI, and IoT, expanding enterprise solutions and emerging markets through strategic alliances and cross-industry collaborations. Furthermore, we will utilize AI to improve operational, network, and energy efficiency, strengthening our resilience and sustainable competitiveness, and creating long-term value for shareholders, customers, employees, and society.
  • User Growth & Revenue Performance
  • Number of Projects and Participants

Risk Culture

Regular risk management education for all non-executive directors
In accordance with Article 40 of《Corporate Governance Best Practice Principles》, the Company requires directors to complete at least three hours of risk management training annually to enhance their relevant capabilities. Training programs for directors please reference the company annual report P.41. Annual report

Focused training throughout the organization on risk management principles
In order to fortify risk response competency of employees and cultivate risk management culture, we conduct risk management trainings every year with topics such as how to conduct risk management and information security. We also test employees with simulated phishing attacks. Such trainings and simulation sessions aim to enhance awareness of employees and train them to respond effectively in accordance with Company's regulations. Consequently, creating risk management culture within the company is a responsibility for all employees, ensuring sustainable business operations. In 2023, the total number of hours for the risk management course is 78,032.6 hours. In 2024, the total number of hours for the risk management related courses is 96903.8 hours. In 2025, the total number of hours for the risk management related courses is 137,136.55 hours.

New employee orientation programs include risk management, such as code of conduct, information security training, labor safety and health, and prevention of discrimination and harassment. These programs aim to enable new employees to understand our company culture and our stand on risk.

Financial incentives which incorporate risk management metrics
Employees are encouraged to propose suggestions on how to lower risks and improve the performance and quality of their work while achieving objectives. Awards will be given to employees in recognition for suggestions deemed valuable to the company, and these credits will be noted in their evaluation. Employees with better performance will receive higher bonus and salary increase. On the contrary, if an employee violates the regulations of internal control system or information security policy, the employee may be recorded a warning, and may not receive a rewarding performance evaluation. The poor performance ranking will lead to a lower bonus and salary adjustment.

Incorporation of risk criteria in the development of products and services
As a telecommunications provider of critical infrastructure, Taiwan Mobile fully recognizes that the stability and security of IT systems are of utmost importance. Accordingly, in the development and maintenance of our information systems, we not only adhere strictly to security standards but also regard risk assessment as a core element. From requirements planning to daily operations, every stage incorporates comprehensive risk assessments to ensure system stability, availability, and information security, thereby reducing the potential impact of system disruptions or data breaches on our customers and operations. In the development of our IT products and services, we primarily conduct risk assessments across three dimensions: technical architecture and systems, system performance and availability, and information security and privacy.

1. Technical Architecture and Systems Assessment

We focus on ensuring that the system's foundational design is robust and sustainable, preventing architectural issues that could hinder future scalability and maintenance.

Key Areas of Assessment:

  1. Scalability Risk: Evaluating whether the system design has sufficient flexibility to accommodate future business growth and new feature integration. We commonly adopt microservices or modular designs, enabling independent development and scaling of services while reducing interdependencies.
  2. Technology Selection Risk: Assessing the maturity of selected technologies and the extent of community support. We also avoid over-reliance on a single vendor (Vendor Lock-in) to ensure that replacement or integration in the future does not result in excessive costs or technical barriers.
  3. Compatibility Risk: Evaluating the stability of integrations between new systems, legacy systems, third-party services, or APIs. This includes integration testing and the establishment of standardized API interfaces to reduce risks caused by version updates or interface changes.
2. System Performance and Availability Assessment

We ensure that systems can withstand high traffic loads and maintain service stability even under unexpected conditions, thereby delivering a high-quality user experience.

Key Areas of Assessment:

  1. Capacity and Performance Risk: Using stress testing and load testing to simulate peak traffic conditions, ensuring systems remain stable and response times stay within acceptable limits.
  2. High Availability Risk: Preventing single points of failure by adopting redundant designs, such as multi-data center or multi-cloud deployments, with automated failover mechanisms to seamlessly switch to backup systems when primary systems encounter issues.
  3. Disaster Recovery (DR) Risk: Establishing detailed disaster recovery plans, including regular backups and offsite redundancy. We also define clear Recovery Time Objectives (RTO) and Recovery Point Objectives (RPO) to ensure rapid service restoration and minimal data loss in the event of a disaster.
3. Information Security and Privacy Risk Assessment

This is the most critical dimension in our development process, aimed at safeguarding both customer and corporate data while ensuring compliance with international security standards.

Key Areas of Assessment:

  1. Secure Development Lifecycle: Incorporating ISO 27001:2022 and related international standards throughout development, testing, and deployment to uphold confidentiality, integrity, and availability (CIA principles) from the outset.
  2. Secure System Design: Embedding security architecture in early design stages. For instance, identity authentication and access control follow the principle of least privilege, granting users only the minimum level of access necessary.
  3. Pre-Deployment and Operational Security Testing: Conducting code reviews, penetration testing, and vulnerability scans before system launch to eliminate potential threats. Post-deployment, we maintain continuous monitoring, timely updates, and regular reviews to ensure the effectiveness of security measures.
  4. Supply Chain Risk Management: Requiring third-party vendors to comply with international standards (such as 3GPP, ITU, NIST) and provide relevant certifications, thereby reducing risks arising from the software supply chain.

Through these three dimensions of risk assessment, we ensure that our IT products and services not only meet functional requirements but also deliver a stable, efficient, and secure user experience.