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.

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

<p>This entry was provided by the Sabin Center for Climate Change Law. Please see the terms of use for citation and licensing of third party data.</p>

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

Filed

Singapore

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An aim to achieve a quantifiable outcome within a given time-frame, set by an institution such as a national government.

Policy instruments are techniques or tools used by governing authorities to promote certain policies in order to achieve predetermined goals. Put simply, instruments are how a government tries to achieve its goals, with this taxonomy being focused on national policy instruments.

Risk is the potential for adverse consequences resulting from the dynamic interplay between (climate-related) hazards, exposure, and vulnerability of affected human or ecological systems.

Groups  of people who are adversely affected by climate change or the response to it

A set of principles, processes, and practices that build economic and political power to shift from an extractive economy to a regenerative economy.

Justice is the ethical and political framework that addresses fairness, including issues of responsibility, rights, and structural inequity.

Renewable energy means all forms of energy produced from renewable sources in a sustainable manner.

Fossil fuel is a generic term for non-renewable energy sources such as coal, fossil gas, and oil (including crude oil, and petroleum products), that can be used for electricity and heat generation. Fossil fuels are hydrocarbons formed from pressurised and heated organic material buried over millions of years.

Molecules in the atmosphere that play a key role in the greenhouse effect by trapping heat radiating from Earth’s surface.

Area of the economy in which actors engage in identical or related activities.

In human systems, the process of adjustment to actual or expected climate change and its effects, in order to moderate harm, increase resilience or exploit beneficial opportunities. In natural systems, the process of adjustment to actual climate change and its effects; human intervention may facilitate adjustment to expected climate change and its effects.

The management and allocation of funds, assets and investments to meet various objectives

A loan is a policy instrument where funds are provided to a borrower with the expectation of repaying the principal plus interest.

A ban is a legal action that prevents the sale or supply of a product or service, or that recalls a product from the market. Examples are bans on SF6, greenwashing, fossil fuel advertisement or single-use plastics.

An agency providing government-backed financing, guarantees, and insurance to support domestic companies' international exports, that can play a role in financing climate-related projects.

A company that is owned wholly or partially by the state, typically operating in key sectors.

A financial entity operated or controlled by the state, often with a mandate for social or economic development.

A target to reduce the prevalence of a greenhouse gas over a specific time frame

A commitment to balance GHG emissions with removal by a certain point in time, effectively reducing the net emissions to zero

Either money or something of monetary value is transferred between two or more organisations, people or countries.

The release of heat-trapping gases, primarily from human activities such as burning fossil fuels, agriculture and industry.

Replacing technologies that burn fossil fuels directly with alternatives powered by electricity.

Actions to reduce emissions in energy generation and supply.

Technologies that capture and hold energy in reserve for later use.

Production of electricity and heat from solar irradiation.

Oil is a combustible liquid fossil fuel composed mainly of hydrocarbons, occurring as crude oil and refined into petroleum products such as petrol, diesel and kerosene.

Fossil gas, commonly known as natural gas, is a fossil fuel consisting chiefly of methane with smaller amounts of other hydrocarbons and trace gases, found in underground deposits.

Coal is a combustible sedimentary rock formed from carbonised plant matter, rich in carbon and hydrocarbons, and occurring in several main types including hard coal and brown coal.

Any compulsory, unrequited payment to the government levied on corporations or individuals. This can be for environmental reasons, such as introducing a Carbon tax to set a price that emitters must pay for the greenhouse gases they emit.

The activities of industries that transforms raw materials into finished goods through industrial processes.

The activities of industries involved in the production, distribution, and sale of energy, including electricity, gas, and renewables.

Activities that involve planning, designing and building infrastructure, residential, and commercial structures.

This sector involves activities to move goods and people, alongside the storage of products.

Activities of businesses and institutions that provide financial services and products to individuals and organisations.

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

Target

Policy instrument

Renewable energy

Fossil fuel

Greenhouse gas

Economic sector

Finance