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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.

In May 2025, climate advocacy group Solutions for Our Climate (SFOC) filed a whistleblower complaint with Singapore Exchange Regulation’s Whistleblowing Office against Korea Electric Power Corporation (KEPCO), South Korea’s largest electric utility, concerning KEPCO’s approximately US$11 billion Global Medium Term Note (GMTN) program listed on SGX. SFOC alleges that KEPCO failed to disclose material climate‑related risks in its offering documents, potentially breaching Singapore securities disclosure requirements and SGX Mainboard Rules on providing sufficient information for investors to obtain a “full and proper understanding” of an issuer’s business, financial condition, prospects, and risks, and to include information that such investors would customarily expect to see in such documents.

The complaint claims KEPCO omitted disclosure of its: (1) continued reliance on coal‑fired power generation until 2050, misaligned with global decarbonization goals and the Paris Agreement; (2) financial exposure to liquefied natural gas (LNG) price volatility, amid declining global demand and delays or cancellations in key LNG infrastructure projects; and (3) misrepresentation of hydrogen-LNG and ammonia-coal blends as "carbon-free" in regulatory and investor communications, contrary to emerging international standards. SFOC's complaint is outlined here: https://forourclimate.org/newsroom/1081

As of late 2025, SGX has acknowledged receipt of the complaint and stated that it will review the matter and take necessary action, but no public enforcement decision has been announced.

On February 15, 2023, a whistleblower complaint was submitted by NGO Market Forces to the Singapore Exchange alleging that JERA Co. Inc. (JERA) failed to disclose material information regarding its US$300 million bond issued on April 14, 2022. The complaint asserts that: 

(1)	JERA allegedly failed to disclose risks related to its significant exposure to the LNG value chain and climate transition risks. These risks allegedly include (i) the impact of the Russia-Ukraine war on JERA’s business, including downward revision of LNG demand due to volatility and high prices; (ii) JERA’s lack of analysis in demonstrating alignment with the Paris Agreement or risks posed by the IEA's "Net Zero by 2050" scenario, unlike peers in the industry; (iii) JERA’s alleged reliance on unproven technologies like ammonia and hydrogen co-firing without disclosing cost assumptions or acknowledging past failures in carbon capture and storage; and (iv) that JERA would be affected by a rapid transition to renewable energy that may undercut the LNG industry, as JERA’s generation assets are allegedly predominantly gas-fired, with only 2% coming from renewables, and JERA allegedly has not disclosed plans for a rapid capital shift toward renewables despite market trends.
 
(2)	JERA allegedly has not disclosed specific litigation cases, which could have a material effect on JERA’s future financial prospects, thereby preventing investors from making an informed assessment of the company's prospects. The litigations cases are (i) Litigation by Tiwi islanders concerning the Barossa Gas Field in Australia, which resulted in the Federal Court of Australia invalidating the project's environmental permits due to lack of consultation. JERA holds a 12.5% stake in this project; (ii) Litigation regarding environmental impact assessments the Yokosuka coal power plant project, in which there is a risk of permit cancelation for the project if litigation is successful. Further, JERA has failed on an ongoing basis to disclose developments in litigation proceedings as these developed. 

As a consequence, Market Forces alleges that JERA is in violation of the Securities and Futures Act (SFA) (and its subsidiary legislation, Offers of Investments Regulation 2018) and the Singapore Exchange Rulebook Rules 603, 243 and 323. These respectively have the following requirements: 
(i) SGX Rule 603: Requires offering memoranda to include sufficient detail for investors to understand the issuer's business, financial conditions, and risks.

(ii) SFA Section 243: Mandates that a prospectus contain all information investors reasonably require to make an informed assessment. The Offers of Investments Regulation 2018 (subsidiary legislation) further prescribes a checklist of information that must accompany the prospectus of a debenture, such as “risk factors that are specific to the relevant entity and its industries” and legal or arbitration proceedings that “have a material effect on the financial position or profitability of the relevant entity”.

(iii) SGX Rule 323: Imposes a continuing disclosure obligation for information that may materially affect the price or value of debt securities.
Market Forces' complaint is available here: https://www.marketforces.org.au/wp-content/uploads/2023/02/20230215_SGX_JERA-CO-US300M-3.665B270414_omission-of-material-information.pdf

As of late 2025, there have been no reports of public disciplinary action by the Singapore Exchange regarding this whistleblower complaint. 

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