台灣商銀是否協助綠色資金流向永續—綠色授信業務與反漂綠措施之研究

Abstract

因近年全球永續關注度增加，各界也不斷更新目標、相關法規、改善行動等，其中，氣候變遷以及永續環境之議題更是各界討論重點，故興起「綠色金融」，綠色經濟時代來襲，各企業機構以友善環境為目標所創建之綠色金融商品或服務儼然成為國際發展趨勢，然而，隨投資方與消費方的永續觀念建立愈趨完全、綠色金融市場擴大與相關產品服務增加，「漂綠 (Greenwashing)」問題逐漸浮現，不僅可能對環境產生負面影響，也是誤導投資方與消費者，進而威脅到綠色金融市場的健康發展。而台灣目前雖然幾乎所有銀行皆簽署赤道原則，逐漸將綠色及永續影響納入授信及融資評估中，法律面也推出《氣候變遷因應法》等規範鼓勵揭露品質，並有綠色金融戰略作為企業方針，但仍未有直接針對漂綠的專法。 法規上路前，與多方企業及機構資金流向息息相關之商銀或其他金融機構，可謂其中第一線守門人，希望在法規明確前能先為永續把關、在法規上路後能隨時跟進並配合，確保資金流向正確，作真正永續環境之助力，例如許多銀行已致力於推行綠色授信等業務，並研擬評估方式、根據不同產業設置不同達成標準。然透過研究調查，仍有可以精進之處，便於銀行及客戶雙方未來更好與世界接軌、更能確保資金真正流向永續，具體如銀行本身之永續戰略與行動改善、制度與永續之連結、防漂綠措施之精進等，故本研究希望針對銀行授信與防漂綠措施進行探討，並透過訪談與Ｚ企業個案研究提供台灣商銀未來發展建議做為參考。 透過Ｚ企業個案研究可發現除了法規配合，其有更多值得台灣商銀學習之處，包含整體公司之永續戰略、由上而下之永續領導方式、成立多個永續相關團隊、建立自身氣候評估架構、碳指南、各產業客戶之排放目標，以及具體如何將各界利害關係人納入永續戰略中，另外，Ｚ企業公布之防漂綠挑戰釐清及對策也十分值得學習，其透過實務經驗、挖掘問題與分析，其認為數據佐證為一大決策要點，而為了提高數據品質、及時性與可用性，正確測量排放量並隨時間監測進展為Ｚ企業認為之關鍵包含測量與估算、數據滯後、方法可比較性，以及新興減碳技術數據之匱乏，並針對各挑戰以自身資源提出應對方法，例如以直接測量法協助企業代替估算、提供保證增加可信度、採用瀑布計算法解決數字空白、嚴格之審查方始使數據滯後減少等。 最後本研究將針對台灣現況提出未來發展之建議，除了法規與整體環境尚待精進外，具金流責任之銀行還能如何協助台灣成為易於推動綠色金融及永續之環境。例如建議台灣商銀將永續概念納入公司運營策略中、建立推動永續之文化，並由上而下領導；於向下推行時，透過將績效與永續之連結，增加員工推動力；針對漂綠問題成立解決團隊，協助銀行業務同時也可更好協助客戶作真正綠色轉型。

In recent years, with the increasing global focus on sustainability, various sectors have continuously updated their goals, relevant regulations, and improvement actions. Among these, the issues of climate change and sustainable environments have become key discussion points. This has led to the rise of "Green Finance." However, as the concepts of sustainability among investors and consumers become more comprehensive, and the green finance market expands with more related products and services, the problem of "greenwashing" has gradually emerged. Greenwashing can negatively impact the environment, mislead investors and consumers, and threaten the healthy development of the green finance market. Although Taiwan currently has regulations such as the Climate Change Response Act and the Fair Trade Act that encourage quality disclosures, as well as green finance strategies for corporate guidelines, there is still no specific law directly targeting greenwashing. Before these regulations are implemented, commercial banks and other financial institutions, which are closely linked to the capital flows of various enterprises and institutions, can be seen as the frontline gatekeepers. It is hoped that they can first ensure sustainability before the regulations are clearly defined and follow up immediately once the regulations are in place to ensure the correct flow of capital, thus contributing to a truly sustainable environment. For example, many banks have already committed to promoting green credit businesses and are developing assessment methods and setting different achievement standards based on various industries. However, through research and investigation, there are still areas for improvement. This would help both banks and their customers better align with global standards and ensure that funds genuinely flow towards sustainability. Specific areas for improvement include the bank’s own sustainable strategies and actions, the connection between systems and sustainability, and the enhancement of anti-greenwashing measures. Therefore, this research aims to explore bank credit and anti-greenwashing measures, providing future development suggestions for Taiwanese commercial banks through interviews and case studies of Company Z. From the case study of Company Z, it can be found that in addition to regulatory compliance, there are many aspects worth learning for Taiwanese commercial banks. These include the company's overall sustainability strategy, top-down sustainable leadership, the establishment of multiple sustainability-related teams, the creation of their own climate assessment framework, carbon guidelines, emission targets for clients in various industries, and how to integrate various stakeholders into the sustainability strategy. Additionally, the challenges and countermeasures related to anti-greenwashing published by Company Z are also highly instructive. Through practical experience, problem identification, and analysis, Company Z believes that data substantiation is a major decision point. To improve data quality, timeliness, and usability, accurate measurement of emissions and continuous monitoring of progress over time are deemed crucial by Company Z. This includes measurement and estimation, data lag, methodological comparability, and the lack of data on emerging carbon reduction technologies. They also propose solutions based on their resources for each challenge, such as using direct measurement methods to assist enterprises instead of estimation, providing guarantees to increase credibility, adopting waterfall calculation methods to address data gaps, and strict audits to reduce data lag. Finally, this research will propose future development suggestions for Taiwan's current situation. Apart from regulations and the overall environment that still need improvement, how banks, with their responsibility for capital flows, can help Taiwan become a more favorable environment for promoting green finance and sustainability. For example, it is suggested that Taiwanese commercial banks incorporate the concept of sustainability into their operational strategies and establish a culture of promoting sustainability with top-down leadership. When implementing these strategies downward, linking performance with sustainability can increase employee motivation. Additionally, setting up teams to solve greenwashing problems can help banking businesses and better assist customers in achieving a true green transition.