Company Governance

Risk Management

Risk Management

The Company's risk management organizational structure includes the Board of Directors, the Sustainable Development Group (ESG Group), the Risk Management and Control Group, the Audit Office and various business execution units.

The company has a Risk Management Sub-group under its Sustainable Development Task Force. The risk management sub-group is the responsible unit for implementing risk management, which is responsible for the overall risk management issues, including presenting risk management reports, integrating and coordinating cross-departmental common risk management issues, publicizing and communicating important risk management issues, and reporting the implementation to the Sustainable Development Group on a regular basis, and the corporate governance supervisor reports the implementation of risk management to the Board of Directors every year.

In order to strengthen the vision of corporate governance and sustainable development and establish an effective risk management mechanism, The Company has formulated "Risk Management Policies and Procedures" as the basis for the implementation of risk management at all levels of The Company. Risk management policies and procedures clearly specify that risk management covers strategic risks, operational risks, financial risks, information risks, legal compliance risks, credit risks, and other emerging risks (such as risks related to climate change or infectious diseases), and all business execution units shall identify, analyze and evaluate risks and take appropriate risk response measures. And fill in the risk category, risk items, risk management strategy or response measures, risk assessment description and risk acceptance (quantifiable (including control objectives and risk limits) or qualitative) in the risk management and control project table, and then submit major risk items related to the company's operation to the risk management and control group for discussion and formulation, and then the sustainable development group will review and approve them.

For the approved risk items, the business execution units shall adopt risk management strategies or response measures, and compile and review the implementation situation every month, control and supervise it in the risk control sub-group every quarter, and then report it to the sustainable development group for review on a regular basis.

2024 Risk Management Strategies or Countermeasures

Strategic Risks

Environmental Sustanability Strategic Risks (E)

  • Advance Greenhouse Gas (GHG) Reduction Technologies
    • Process improvement, replacement or modification of energy-consuming equipment; investment in developing green energy (solar power plants), effective management of energy and water conservation and resource (water/electricity) utilization (smart management); resource recycling and waste reduction (waste heat recovery, wastewater recycling).
    • Participation in regional resource integration (oxygen, argon, nitrogen, and steam supplied by China Steel, recycled water, renewable energy, etc.).
  • Evaluate multiple solutions simultaneously, including green energy, energy storage, green electricity certificates, and carbon sinks (forests/oceans/soil), based on principles of cost-effectiveness and sustainable development.
  • Plan investments in energy-saving, low-carbon innovative technologies (quantum electric furnaces, hydrogen energy, etc.) and carbon capture and storage technology (CCUS). The short-term goal is a 10% reduction by 2025; the mid-term goal is a 47% reduction by 2030; the long-term goal is to achieve net-zero emissions (or carbon neutrality) by 2050.

Operational Risks

Production Risk (G)

  • Depending on the basis of the Business Department's estimated orders, plan production and sales targets, and dynamically adjust the production line to match production.
  • Appropriately plan the schedule of subcontracted hot-rolling operations, and seek assistance from domestic excellent hot-rolling manufacturers in due course.
  • Ensure the quality and quantity of steelmaking raw material deliveries, and monthly monitor and compare whether raw material and nickel metal input and output are normal; continuously monitor whether various steelmaking process parameters are stable.
  • Establish appropriate spare parts management methods to prevent production line shutdowns due to material shortages.
  • Build a maintenance knowledge base through maintenance cases, which can be used for inquiries in case of equipment failure, so as to shorten the maintenance time and quickly resume production.
  • Implement autonomous quality control in each unit and actively collaborate with quality assurance to prevent batch defects, enhance inspection capabilities, and provide timely warnings to reduce the risk of batch defects.

Sales risks (G)

  • Stabilize existing customer base: Through monthly customer visits, fully understand distributor and market demands, and build long-term cooperation models to effectively consolidate loyal customer groups.
  • Adjust raw material procurement volume: Our company does not sign long-term contracts for raw material procurement. In response to rapid market changes, we timely convene meetings for review, flexibly adjust and leverage the advantages of a nimble procurement strategy to reduce the risk of inventory price drops.
  • Propose flexible order acceptance models: To increase monthly order volume, propose special sales programs for certain products at pricing meetings to effectively improve equipment utilization rates.
  • Expand the breadth of export orders: Continuously seek partners in markets such as Europe, America, and Southeast Asia, and gradually build distribution channels to reduce the risk of over-concentration in sales regions.

Business Environment Risk (G)

  • Tsingshan Holdings Group, China and Indonesia use laterite nickel to smelt stainless steel, and sell it in the global market with low cost advantage. Taiwan's stainless steel industry has a high cost of raw materials, resulting in an oversupply of steel coils. Therefore, the Company continues to reduce production costs and develop new steel types Increase added value to enhance product competitiveness.
  • The key indicators of operation are mainly: gross profit rate, operating profit and loss, pre-tax profit and loss, capacity utilization rate, inventory balance, idle capacity loss and inventory profit and loss, etc. The Accounting Office regularly produces relevant management reports every month for regular monitoring by responsible units.

Raw Materials & Supply Chain Risk (G)

  • To ensure the supply of stainless steel scrap and ferrochrome raw materials, based on production and sales planning needs, secure the procurement of stainless steel scrap and ferrochrome raw materials for steelmaking production.
  • Control the low-cost inventory model for black coil, and adopt a flexible application mechanism for black coil procurement and steelmaking replacement costs.
  • Actively procure and develop nickel-based raw materials for use as steelmaking ingredients.

Supplier Management Risk (S)

  • When purchasing raw materials from foreign suppliers, a purchase contract must be signed, which clearly stipulates that the supplier should abide by local laws and regulations, including labor and human rights related laws and regulations.
  • Suppliers must also clearly provide the source of their raw materials, so as to filter and avoid obtaining raw materials produced by upstream manufacturers that violate international regulations or consensus.
  • In terms of raw material supplier management mechanism, there is a rejection list of manufacturers and JIS MARK supplier evaluation. Through the above-mentioned procurement procedure specifications and review mechanisms, suppliers can be managed and screened for pre-qualification and contract performance capabilities.

Inventory Risk (G)

  • The supply and demand of important raw materials vary greatly, which makes it difficult to grasp the procurement of raw materials, and inventory fluctuates greatly. In addition, some steelmaking raw materials are purchased from imported sources. Due to force majeure, the material sources may sometimes not be delivered on schedule and the steelmaking output varies greatly, which may easily lead to a shortage of material sources.
  • Implement production and sales targets to control inventory, and control the total inventory of WIP to a reasonable level.
  • Master inventory causes warehousing pressure and company cost backlog. Strengthen the management and control of monthly master inventory to reduce production costs and strengthen capital income. Control targets and risk limits exclude the following items: deferred exports, coordination with shipping schedules, and cross-month orders.

Labor-management Relations Risk (S)

  • Hold regular labor-management meetings and discussions, communicate and solve labor-related issues in a timely manner, establish labor-management consensus, and reduce labor-management disputes.

Human Resources Risk (SG)

  • In order to be able to use sufficient manpower in a timely manner in the future, the recruitment schedule will be planned according to the retirement time of the retirees in the next year, and the recruitment will be carried out regularly according to the number of employees required.

Occupational Safety and Health Risk (S)

  • Set up a dedicated occupational safety and health unit (Safety and Health Department) and dedicated personnel to supervise the company's safety and health management matters.
  • Continue to implement ISO 45001 occupational safety and health management system, and carry out risk control by systematic management.
  • Carry out occupational safety and health hazard identification and risk assessment, and adopt corresponding management, supervision and improvement measures, and establish safety operation standards to reduce related risks and prevent occupational accidents.
  • Formulate an operating environment monitoring plan, and regularly entrust an operating environment monitoring organization approved by the Ministry of Labor to carry out monitoring.
  • To engage in special operations, apply for a permit from the organizer, and only start work after obtaining the permit.
  • Conduct emergency response drills on a regular basis, so that colleagues are familiar with various response measures, eliminate disasters as soon as possible, and reduce and mitigate the impact losses caused by hazards.
  • Follow the Ministry of Labor's Occupational Safety and Health Education and Training Regulations and implement regular safety and health education and training for employees.

Process Safety Risk (SG)

The processes related to hydrofluoric acid, as well as ammonia tank and nitric acid equipment is a high-risk chemical process of the Company. Strengthen control is carried out.

The main measures are as follows:

  • Establish standard operating procedures and conduct education and training.
  • Implement daily regular automatic inspection and regular inspection.
  • Conduct regular emergency response drills.
  • Conduct audit inspection every year.

Financial Risk

Currency Risk (G)

  • When the U.S. government releases monetary policy-related news every week, better observe exchange rate trends, so as to buy at a relatively low price and grasp the lower average cost to cover the payment in U.S. dollars.
  • For monetary liabilities denominated in other foreign currencies, by buying or selling foreign currencies at the instant exchange rate, the net exposure risk is maintained at an acceptable level.

Liquidity Risk (G)

  • Control the liquidity ratio and quota utilization rate.

Information Security Risk

Information Security Risk (G)

  • Regular data backup and recovery training for important information systems and data files; establish auxiliary and replacement computer equipment and emergency power facilities, strengthen monitoring, anomaly management, and backup, and set up early warning notifications to reduce the risk of information system interruption.
  • Install firewall systems to defend against illegal external network packets, enhance intrusion prevention, block spyware, and improve protection against unknown attacks; set up antivirus servers to constantly detect the network and prevent computer virus intrusion and spread; build a cybersecurity zone defense system to isolate and eliminate virus infection spread, thereby strengthening information security protection.
  • Implement a fingerprint access control system in the computer room to manage personnel entry and exit, prevent unauthorized personnel from entering, and ensure the security and confidentiality of computer room equipment.

Environmental Risk

Climate Change Risk (E)

  • In response to changes in government laws and policies related to climate change, formulate energy-saving and carbon-reduction implementation plans.
  • Carry out inventory and verification of greenhouse gas emissions to discuss reduction goals and benefits.
  • In line with Taiwan's greenhouse gas reduction policy, set annual voluntary greenhouse gas reduction targets to reduce emissions and reduce impacts.
  • Continuously report the Company-wide greenhouse gas voluntary reduction plan and performance every year.
  • Collect and calculate product carbon content information for the EU CBAM transitional period.
  • In response to the preliminary plan for carbon neutrality, implement the green power policy, build green power to reduce carbon emissions, and strive to obtain carbon rights.

Environmental Protection (E)

  • Regularly monitor and analyze and effectively control the quality or quantity of industrial waste. For the slag produced in the steelmaking process and the inorganic sludge produced by wastewater treatment facilities, all meet the requirements and can be cleared by legal recycling organizations for removal and reuse.
  • Strengthen the maintenance of pollution prevention and control equipment to maintain normal operating functions, and closely monitor the quality of pollutant emissions (such as nitrogen oxides, sulfur oxides, etc.) to comply with operating permits and relevant environmental regulations.

Water Management Risks (E)

The iron and steel industry is one of the industries with highest water consumption. In order to effectively use water resources, formulate water-saving strategies and set up water-saving facilities, such as improving system design, adopting high-efficiency equipment, recycling and reusing, and adding water storage pools for backup to cope with water shortages question.

Compliance Risk

Compliance Risk (G)

  • Each unit regularly conducts regulatory compliance checks. In the event of any non-compliance, it is required to correct and improve or formulate relevant operating procedures to reduce the risk of violations.
  • Each unit conducts publicity or education training from time to time.
  • Monthly, collect and compile amendments to occupational safety and health, environmental protection, and climate change-related regulations. After applicability identification, each unit conducts a compliance check. Non-compliant items must be immediately improved or management plans for improvement must be established and executed.

Integrity Management Risk (G)

The Company has an Integrity Management group, and in accordance with Article 7 of the Company's Integrity Management Code (scope of prevention plans), the following illegal situations are prevented:

  • Giving and accepting bribes.
  • Providing illegal political donations.
  • Improper charitable donations or sponsorships.
  • Offering or accepting unreasonable gifts, entertainment or other improper benefits.
  • Violation of business secrets, trademark rights, patent rights, copyrights and other intellectual property rights.
  • Engaging in acts of unfair competition.
  • Products and services that directly or indirectly damage the rights, health and safety of consumers or other stakeholders during research and development, procurement, manufacture, provision or sale.

Other Risks

Property Risk (G)

The Company has property insurance for buildings or equipment such as offices, workshops, instruments, and wealth-generating appliances to reduce losses caused by disasters.


  1. The above-mentioned risks are determined by each business executive unit to formulate various management and control strategies or measures based on their rights and responsibilities, so as to control the risks to an acceptable range.
  2. ESG stands for Environmental, Social, Corporate Governance.