Action for Climate Change
CLC Environmental Sustainability Strategy
CLC's sustainability policy centers on smart low-carbon operations, resource circulation, and environmental stewardship, fully integrating sustainability into business operations and management decisions. CLC implements life cycle management from product design and process optimization to resource recovery and reuse, advancing carbon reduction and environmental protection. This policy guides all employees and underpins CLC's net zero transition and climate resilience, strengthening its competitiveness in the global sustainable supply chain.
Policy Promotion and Management Mechanism
CLC's sustainability policy is overseen by the taskforce under the
Sustainability Committee and the Risk Management Committee, and is
integrated into the ISO management systems of the parent company (including
all mills/plants) and its domestic and overseas subsidiaries to ensure
comprehensive implementation.
In parallel, stakeholder engagement mechanisms have been established,
collaborating with customers, suppliers, communities, and academic
institutions to implement projects on environmental education, nature-based
solutions, and green innovation, building a sustainable governance network
to advance a clean and resilient future through Governance Co-creation.
CLC Management Verification
CLC manufactures recycled paper using clean production technologies to
achieve environmental benefits and sustainable resource utilization. The
company implements FSC™ international forest management standards and has
adopted ISO 9001 quality management system, ISO 14001 environmental
management system, and ISO 50001 energy management system certifications at
all mills/plants in Taiwan.
Adhering to the principle of sustainability, CLC extended its successful
experience to overseas operations by implementing ISO 9001 and ISO 14001
management systems at all sites in Mainland China and Vietnam. In 2022, CLC
launched ISO 50001 energy management and ISO 45001 occupational health and
safety management systems. As overseas production capacity continues to
expand, CLC is introducing additional international standards management
systems at new plants to strengthen sustainability and energy efficiency,
ensuring global operations comply with the highest environmental and safety
standards.

Enhancing Climate Risk Governance and Advancing Low carbon Smart Paper Transformation
CLC aligned with international frameworks to mitigate climate change
impacts on operations and finances and strengthen organizational climate
resilience. In 2021, CLC became the first paper company in Taiwan to
pass the TCFD audit and receive the highest rating, establishing a
comprehensive climate risk and opportunity identification process and
conducting ongoing TCFD reassessments based on major climate policy
developments.
In 2024, CLC became one of the first global Early Adopters of the
Taskforce on Nature related Financial Disclosures (TNFD), strengthening
its focus on nature-related issues. CLC also implemented Internal Carbon
Pricing (ICP), launched the IFRS Sustainability Disclosure Standards
implementation plan, and completed the greenhouse gas inventory for
consolidated subsidiaries.
By 2025, CLC will expand ISO 14064-1 GHG inventory assurance to all
consolidated subsidiaries and initiate an NTD 7.7 billion
sustainability-linked syndicated loan to accelerate Low-carbon Smart
Paper transformation, advancing toward the 2050 carbon neutrality
vision.
CLC Important Milestones on Climate Governance
Advancing International Standards for Climate Resilience and
Information Transparency
The circular economy is a practical approach to achieving low-carbon net
zero. CLC treats climate change risks as opportunities, focusing on
S.M.A.R.T. Low-carbon Intelligent Paper and establishing circular
economy sites domestically and internationally. CLC invests in recovered
paper recycling, prioritizes Paper-based Solutions (PBS) as Nature-Based
Solutions, and advances climate governance to enhance operational
resilience.
Since 2005, CLC has implemented emission reduction management on
production lines after obtaining the world's 1st ISO 14064-1 GHG
inventory certificate. In 2008, CLC obtained Taiwan's 1st international
VCS carbon credit certificate, and in 2010, Taiwan's 1st carbon
footprint label for household paper products. In 2023, CLC formed a
Carbon Reduction team with the industry chain and completed Taiwan's 1st
product carbon footprint inventory for industrial paper. In 2024, CLC
launched a climate questionnaire survey for key Tier 1 domestic and
international suppliers to enhance supply chain carbon data management
and accelerate zero carbon transition opportunities.
CLC adopted international frameworks to reduce climate-related
operational and financial impacts and achieved the Corporate Governance
3.0 goals ahead of schedule. In 2021, CLC became the 1st pulp and paper
company in Taiwan to pass the TCFD audit and receive the highest rating.
In 2022, CLC initiated greenhouse gas inventories for subsidiaries.
Vietnam Binh Duong Paper Mill obtained the 1st ISO 14064-1 GHG inventory
certificate in the local pulp and paper industry, with subsequent
expansion to other overseas plants. By 2024, all 37 consolidated
subsidiaries completed ISO 14064-1 GHG inventories, with key plants
completing third-party assurance. CLC will continue to expand
third-party assurance for consolidated subsidiaries' greenhouse gas
inventories, targeting full completion by 2026.
From Climate to Nature: Shaping Forward-looking Sustainable Low-carbon Strategies
By completing the CDP Climate Change Questionnaire since 2022, CLC has
disclosed climate information and enhanced sustainability resilience. In
the 2023~2024 Year evaluation, it reached Management Level and, in 2024,
was included in the Supplier Engagement Assessment (SEA) A List. The
company continues to strengthen carbon management, promote low-carbon
development, and implement climate adaptation strategies to accelerate
the global sustainability transition. In the same year, CLC became the
first TNFD Early Adopters in Taiwan's paper industry. Under the TNFD
frameworks, the company assessed the dependence and impact of its
business activities on natural resources and, together with industry,
government, and academia, launched research projects on nature and
biodiversity at its sites, establishing a foundation for localized
natural science research.
Advancing the Low-carbon Smart Paper transformation, CLC leverages
digitalization to expand green production and sales, while integrating
product, energy, and water circularity with agricultural and forestry
cycles to enhance the regeneration of plant fibers, bioactive materials,
and biofuels, thereby establishing the 3R PLUS circular economy
blueprint. Digital carbon management has been implemented, with four
scientific carbon-reduction pathways defined: improving energy
efficiency, developing renewable energy, advancing circular low-carbon
fuels, and innovating carbon-negative technologies. CLC participates in
national carbon reduction programs, including the Tayuan Paper Mill's
involvement in the Industrial Development Administration's Industrial
Low-carbon Transition Program. Through academic collaboration, it
integrates R&D and cross-industry expertise to research negative
emission technologies such as carbon fixation and carbon sequestration,
and promotes natural carbon sink development to address climate
change.
To ensure the implementation of carbon reduction actions, CLC has
adopted a top-down strategy, integrating GHG emission reduction and
energy resource efficiency into operational performance indicators. An
annual carbon reduction competition encourages innovation proposals and
recognizes achievements. In 2024, the Taiwan Parent Company's GHG
emissions decreased by 9.38% compared to the base year, achieving
short-term goals ahead of schedule.

Climate Risk and Opportunity Governance
Climate governance at CLC is led by the BoD, with the sustainability
committee and risk management committee responsible for managing
climate-related risks and opportunities. The Climate Change and Circular
Economy Office, under the sustainability committee and led by the
President, coordinates climate risk mitigation, adaptation, and
Low-carbon Transition actions. This office operates within the company's
risk management and business unit management systems, executes risk
management decisions, and coordinates cross-departmental risk
management. Climate-related risks and opportunities are regularly
reported to the BoD to ensure a top-down supervisory mechanism.
Aligned with the Paris Agreement target of limiting global temperature
rise to 1.5℃ by 2100, CLC has, for three consecutive years, been
recognized as a top performer in the CommonWealth Magazine Corporate
Carbon Reduction Thermometer. In 2022, CommonWealth Magazine launched
the Corporate Carbon Reduction Thermometer Platform (TRIPs), applying
international standards and model verification to systematically collect
and assess the carbon reduction commitments and results of Taiwanese
companies against the 1.5℃ target. In 2024, data from 1,200 companies
were collected. The June 2025 report determined CLC's carbon reduction
temperature at 1.511℃ , ranking the company among 405 companies with
high performance.
Climate Risk and Opportunity Strategy
Through annual third-party verified GHG inventories, CLC assesses Carbon
Reduction performance and implements climate change mitigation and
adaptation in line with international initiatives.
Focusing on energy management, CLC addresses Scope 1 direct emissions
and Scope 2 indirect emissions from electricity use. The company has
obtained both wind power and solar photovoltaic renewable energy
certificates, implemented AI management, and integrated a digital
inspection system to enhance green production efficiency. Notably, CLC
was the first paper company in Taiwan to adopt intelligent production
and sales.
To accelerate net-zero transformation, CLC has established strategies
and response plans for major climate risks and opportunities, ldefining
4scientific carbon-reduction pathways: improving energy efficiency,
expanding renewable energy, advancing circular low carbon fuel, and
innovating carbon-negative technologies. Through the S.M.A.R.T.
Low-carbon Paper Strategy, CLC is building 3R PLUS resource circulation,
developing a circular low-carbon biomass material ecosystem, focusing on
paper-based Nature Sustainability solutions, and expanding low-carbon
product opportunities.
To advance low-carbon transition and conduct financial risk assessments
and stress tests, CLC used historical costs from energy saving and
carbon reduction projects as the reference for internal carbon pricing.
In 2024, Tayuan Paper Mill was designated as the first demonstration
site, referencing international carbon pricing trends, global reports,
national carbon fee rates, and industry benchmarks to review carbon
reduction strategies and systematically assess the overall benefits of
its carbon reduction investment portfolio. CLC established a
standardized internal carbon pricing assessment framework, extending it
to all domestic and overseas sites to evaluate the effectiveness of
energy-saving and carbon reduction projects. Each mill or business unit
calculates carbon costs in management reports to inform capital
investment strategies and major decisions.
In addition, CLC partnered with National Chung Hsing University to
establish Asia's 1st Circular Economy Research Institute, advancing
circular reuse of agricultural and forestry surplus materials, the 3R
PLUS Total-cycle carbon reduction manufacturing chain, and a circular
low-carbon biomass resource ecosystem. In 2023, CLC and National Central
University conducted a potential assessment and business model study for
the Tayuan carbon sequestration pilot site, establishing the nation's
1st Carbon Capture, Utilization, and Storage (CCUS) model for carbon
dioxide capture, reuse, and geological storage, supporting progress
toward 2050 carbon neutrality goals.
To manage climate change risks, CLC follows the TCFD framework, conducts cross-department identification of climate-related risks and opportunities, quantifies financial impacts, and develops response strategies. A total of 27 climate change risk and opportunity items have been identified, covering all operational sites in Taiwan, including all mills/plants.

Climate Risk and Opportunity Scenarios
CLC assessed transition risks and opportunities using the national
net-zero emissions pathway. Physical risks and opportunities were
evaluated with TCCIP data and the IPCC Sixth Assessment Report's SSP5-8.5
scenario. The TCFD risk classification framework was applied to identify
transition and physical risks and opportunities, considering current and
emerging climate-related regulations. Scenario risk factors were
quantified for financial impact and likelihood based on established
mitigation and adaptation capacities. Analysis showed that extreme climate
events and long-term changes resulted in financial impacts of less than
0.1% of revenue.
*Note: For climate-related disclosures of listed and OTC companies,
including climate change risks, opportunities, and response measures,
please refer to Annual Report 2024 P40~P42
Major Climate Change Risks and Opportunities Assessment Results
CLC assessed short-term (1~3 years), medium-term (3~5 years), and
long-term (5~10 years) risk exposures based on likelihood and financial
impact,
identifying 6 major transition risks, 2 physical risks, and 4 climate
related opportunities with corresponding financial impacts. Targeted strategies were developed to strengthen risk management and
operational resilience. TCFD assessments continue to cover domestic and
overseas operations to quantify climate-related risks, opportunities, and
financial impacts, supporting carbon reduction pathways, setting short-,
medium-, and long term goals, and accelerating low-carbon development and
climate adaptation strategies.

Major Climate Risk and Opportunity Strategies and Key Performance
Indicators
CLC is advancing the Low-carbon Smart Paper transformation by leveraging digitalization to expand green production and sales, enhance energy efficiency, and reduce carbon emissions. The company implements four scientific carbon-reduction pathways: improving energy efficiency, developing renewable energy, advancing circular low-carbon fuels, and innovating carbon-negative technologies. CLC promotes circular reuse of agricultural and forestry residues and pursues the 3R PLUS Total Resource blueprint for carbon reduction. Under its risk management framework, CLC manages climate risks and monitors environmental performance through indicators such as greenhouse gas reduction, unit product energy efficiency, waste-to resources ratio, alternative fuel ratio, recovered paper utilization rate for industrial paper, unit product water consumption, and air quality management, with regular progress tracking and review.
GHG Emissions Decreased by 9.38% from the base year, Achieving Short-term
Goals Ahead of Schedule
To align with national GHG reduction goals, CLC's Tayuan Paper Mill
participated in the Industrial Development Bureau's pilot project in 2004.
In 2005, CLC obtained the world's 1st ISO 14064-1 GHG inventory
certificate. From 2006, CLC expanded the inventory mechanism to all mills
in Taiwan and implemented company-wide emission reduction management. In
2008, CLC joined the Industrial Development Bureau's Voluntary Carbon
Reduction Standard program and obtained Taiwan's 1st international VCS
carbon credit certification. In 2016, CLC developed the TMS-II.013 Steam
System Optimization methodology for the pulp and paper industry. In 2020,
CLC registered the No. 1 Paper Machine Steam System Optimization Offset
Project (Project Number: B00196) under the Ministry of Environment
(Taiwan) Greenhouse Gas Offset Project, and will obtain a carbon credit of
64,708 tCO2e in July 2025. In 2022, Vietnam Binh Duong Paper Mill passed
BSI verification and received the 1st ISO 14064-1 greenhouse gas inventory
certificate in the Vietnamese pulp and paper industry, with the inventory
management system extended to all domestic and overseas mills.
CLC set Scope 1 and Scope 2 GHG reduction goals for the parent company,
using 2018 as the base year: 5% reduction by 2025, 20% reduction by
2030, and carbon neutrality by 2050. The Sustainability Committee and
BoD oversee progress and planning quarterly, with annual evaluation of
results.
Low-carbon transition is integrated into operational strategy, centered on
circular economy, low-carbon green energy, and smart innovation. The
S.M.A.R.T. low-carbon paper strategy includes Subtraction is Addition,
Waste to Material, AI leads in Digital Transformation, Recycling drivers
Circulation, and Technologies innovate Manufacture. Four scientific
carbon-reduction pathways are implemented: improving energy efficiency,
developing renewable energy, advancing circular low-carbon fuels, and
innovating carbon-negative technologies. Tayuan Paper Mill participated in
the Industrial Development Administration, Ministry of Economic Affairs'
Industrial Low-carbon Transition Program.
Continuously reducing product carbon emissions intensity
With the full-scale operation of the ChuPei Paper Mill's biomass
cogeneration system, product carbon emissions intensity was significantly
reduced, and the company-wide alternative fuel ratio reached 19.58%. In
2024, CLC's Taiwan Parent Company reported GHG Emission (Scope 1 and 2) of
1,303,889.8472 tCO2e, a decrease of 70,056.3050
tCO2e (5.10% YoY) and a 9.38% reduction from the 2018 baseline,
achieving the 2025 goals ahead of schedule. Carbon emissions intensity per
revenue declined from 47.1727 tCO2e per NTD 1,000,000 in 2023
to 42.4388 tCO2e per NTD 1,000,000 in 2024, a 10.03%
reduction.
*Note: 2023 revenue was calculated based on NTD 29,126 million; 2024
revenue was calculated based on NTD 30,724 million.
In 2024, greenhouse gas emission intensity decreased across business
units: industrial paper was 0.836 tCO2e/tonne of paper (-3.38%
YoY), household products and paperboard were 0.919 tCO2e/tonne of paper
(-31.17% YoY), and Corrugated Container was 0.052
tCO2e/thousand m² (+0.93% YoY).
CLC's 2024 greenhouse gas inventory is conducted in accordance with ISO
14064-1:2018 and verified by a third party under ISO 14064-3:2019.
Category 1 and Category 2 receive reasonable assurance, while Category 3
to Category 6 receive limited assurance. All categories have unqualified
conclusions. Completion is scheduled for August 2025, with full assurance
information to be disclosed by CLC Website - Download December 2025.
In accordance with the Sustainable Development Roadmap for Listed
Companies, all 37 subsidiaries included in CLC's consolidated financial
statements completed GHG Emission inventories in 2024. Subsidiaries' GHG
Emission (Scope 1 and 2) totaled 690,659.2733 tonnes CO2e in
2024, with third-party assurance. CLC will continue to expand third-party
assurance of GHG Emission inventories for overseas subsidiaries and
targets completion for all subsidiaries by 2026.
CLC received multiple low-carbon sustainable transformation awards for its
domestic and overseas plants. CLC participated in over 10 low-carbon
sustainability forums with industry, government, and academia, and opened
its plants for visits to facilitate stakeholder engagement and positive
impact.




Product Carbon Footprint Management for Societal Carbon
Reduction
Industry First: 6 Household Paper Products Awarded Carbon Footprint
Label; Expanding to 12 Items by 2025
CLC advanced Low-carbon Transition, becoming the only company in the
industry with 6 carbon footprint labels for household paper products, with
plans to expand to 12 items by 2025 to increase green consumer options and
support societal decarbonization. In 2024, the ChuPei Paper Mill's biomass
cogeneration system was fully operational, reducing carbon emissions
intensity for household paper products and paperboard by 31.17% and
raising alternative fuel usage to 47.6%. Over 90% of products used
recovered paper, remanufactured food paper containers, and scraps; the
remaining 10% used FSC™-certified pulp. Multiple products received the
Ministry of Environment (Taiwan) Low-carbon Product Award.
CLC applies scientific methods to verify carbon reduction results,
conducts routine carbon management for major products, and advances carbon
reduction initiatives aligned with the national net-zero transition
strategy, Green Lifestyle, to increase its impact on a sustainable
future.

Environmental Management and Environmental Protection Expenditure
CLC categorized environmental expenditures and investments, implemented an
environmental accounting system in 2001, and invested NTD 1.23 billion in
environmental initiatives in 2024. CLC will continue to invest in
enhancing environmental performance.
Environmental Penalties
CLC aims for zero major violations and continues to invest in air, water,
waste, and odor pollution control, implementing management mechanisms to
ensure regulatory compliance. In 2024, CLC recorded no major fines but
identified 8 administrative oversights across 23 plants in the Taiwan
area, including 4 air pollution, 2 water pollution, and 2 waste management
cases, with total fines of NTD 112,000. All deficiencies have been
corrected, personnel training has been enhanced, and preventive mechanisms
have been established. CLC will continue to advance digitalization,
strengthen staff training, optimize SOPs, and increase R&D investment
in advanced equipment to improve environmental management and uphold its
environmental commitments.


