SGX Complaint Regarding Oversea-Chinese Banking Corporation Limited (SGX: 039) Misleading Disclosures

OCBC's Responsible Financing Sector-Specific Policies.

On February 23, 2026, a complaint was submitted by an Australian NGO Market Forces to the Singapore Exchange (SGX) alleging that Oversea-Chinese Banking Corporation Limited (OCBC) has made materially misleading disclosures regarding its climate-related financing exposure. OCBC is a corporation incorporated in Singapore and listed on the SGX, therefore subject to the SGX Rulebooks. At issue is OCBC’s Responsible Financing Policy for Energy, which states it will not finance coal-fired power plants (CFPPs) where corporate-financing clients derive more than 25% (new clients) or 50% (existing clients) of power capacity or revenue from CFPPs. The complaint alleges OCBC has nonetheless provided corporate financing via term loan facilities dated 2021, 2022, and January 2023 to three Harita Nickel Group entities (PT Trimegah Bangun Persada, PT Halmahera Persada Lygend, and PT Halmahera Jaya Feronikel), alongside other co-lenders. Harita has built and is operating new coal infrastructure on Obi Island, Indonesia to power its nickel smelting complex. The nickel complex operates 910 MW of coal-fired capacity out of a planned 1,670 MW (with only 40 MW of solar), accounting for more than 50% of the total capacity out of 2.54 GW coal/1.3 GW solar planned for the full complex. The complaint relies on an external report that the Harita Group is supplying nickel for electric vehicle batteries sold across Europe, China and the United States. However, international nickel buyers are independently committing to supply-chain decarbonization, while the EU’s Carbon Border Adjustment Mechanism (CBAM), separately targets carbon-intensive industrial production, both of which heighten transition risk. The complaint argues that this heightens the transition risk retained by OCBC through its financing relationship with Harita. This exposure may give rise to material climate-related financial risks in the form of heightened credit, regulatory, and reputational risk arising from financing clients whose operations are fundamentally reliant on new coal power in an environment of tightening climate policy, trade measures, and market expectations. The complaint also flags Harita’s emissions trajectory as evidence of the retained transition risk. Harita Group’s reported GHG emissions nearly tripled from 3.74 MtCO2e (2022) to 10.87 MtCO2e (2024). Harita’s own reduction target applies only to operations established in or before 2022 and excludes approximately 73% of current smelting capacity operations that commenced after 2022. Plaintiff further alleges that OCBC’s 25% or 50% coal power thresholds may be insufficient or potentially misleading if it does not account for or manage climate risk exposures through clients’ captive coal power activities. Market Forces argues that OCBC’s disclosures have not provided complete information for investors regarding the true extent of the bank’s exposure to companies reliant on industrial coal power plants. The complaint claims that this omission of information is material to investors’ assessment of the bank’s climate-related transition risk. Market Forces claims that OCBC’s non-disclosure of material information may limit investors’ ability to assess OCBC’s exposure to coal-related transition risks, may mislead investors and contribute to the creation of a false market. This may constitute material omissions as defined by SGX Listing Rules, specifically Rule 703(1) and Rules 711A & 711B as briefed below: Rule 703(1) – Disclosure of material information: Requires an issuer to announce information necessary to avoid the establishment of a “false market” in its securities. Rules 711A & 711B – Sustainability Report: Require issuers to prepare a sustainability report, which, pursuant to SGX’s Sustainability Reporting Guide and Practice Notes, should comprise climate-related disclosures in accordance with IFRS Sustainability Disclosure Standards. The SGX framework recognises that the IFRS Sustainability Disclosure Standards build on recommendations of the Task Force on Climate-related Financial Disclosures (TCFD). Practice Note 7.6 to Rule 711B clarifies that sustainability reporting disclosure does not detract from an issuer’s obligation under Listing Rule 703(1) to disclose information necessary to avoid the establishment of a false market, bringing material sustainability and climate-related disclosures within the scope of SGX’s continuous disclosure regime. As of September 2026, there have been no reports of public disciplinary action by the Singapore Exchange regarding this complaint.