SGX Reporting

Since June 2016, the Singapore Exchange (“SGX”) has introduced the Sustainability Reporting Guide to enhance accountability and transparency significantly. Listing Rule 711A requires all listed issuers to prepare annual sustainability reports describing their sustainability practices regarding the primary components as set out in Listing Rule 711B on a “comply or explain” basis. SGX emphasised that while financial reporting summarises past and present performances, sustainability reporting shows the forward-looking performance of the company on risk management and climate change mitigation.

On 7 March 2024, SGX published a consultation paper to incorporate International Sustainability Standards Board (“ISSB”) Standards into its sustainability reporting rules. GreenCo, a professional ESG advisory firm, empowers Singaporean businesses with Sustainability Reporting and Climate-related disclosures.”

For all financial year commencing
Requirements
1 January 2025
  • Refer to ISSB IFRS S1 and S2 in preparing climate-related disclosures, including Scope 1 and 2 GHG emissions
  • Enhance reporting requirements on a mandatory basis
1 January 2026
  • Disclose applicable categories of Scope 3 GHG emissions
  • Issue sustainability reports at the same time as the annual reports
1 January 2027
  • Report climate-related disclosures in compliance with ISSB Standards

*At the current stage, SGX does not propose to mandate external assurance and transition plans but will review the developments at a future date.

Highlights of the Consultation Paper

Considering the increasing demand for climate-related disclosures from investors and stakeholders, the recommendations require the issuers to refer to both “IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information” and “IFRS S2 Climate-related Disclosures” in preparing their climate-related disclosures, including any (permanent) structural and (temporary) transition reliefs.
To further enhance the quality and credibility of disclosures. SGX is proposing to enhance the requirement to report on all primary components of sustainability report under the Listing Rules from a “comply or explain” basis to a mandatory basis.
To help investors and stakeholders make informed decisions, SGX recommends that the sustainability report should be issued together with the annual report.

Key Contents of SGX Sustainability Reporting

The sustainability report should comprise of the following primary components:

  • Material ESG factors: Identify the material ESG factors relevant to the business and key stakeholders, with the reasons and process of selection described.

  • Climate-related disclosures: Contain climate-related issues disclosures in consistent with the TCFD recommendations.

  • Policies, practices, and performance: Provide descriptive and quantitative information about the Policies, practices, and performance related to identified material ESG factors.

  • Targets: Set out the short, medium, and long-term targets for the coming year in relation to each material ESG factor identified.

  • Sustainability reporting framework: Choose appropriate framework(s) to guide the reporting and provide the reasons of selection as well as the general description of the extent of application.

  • Board statement: Include a board statement to show the role and responsibilities of the Board and the management in sustainability governance, while demonstrating that the sustainability issues have been considered in the business strategy, and the material ESG factors are consistently managed and monitored.

Phased Approach

According to the latest requirements in the Consultation Paper, compliance with the ISSB Standards is also allowed to take place progressively.

Primary Components

Adoption
Material ESG factors
  • Addressed most critical factors
Climate-related disclosures
  • Described climate-related disclosure with reference to ISSB Standards based on four pillars
  • Disclosure of Scope 1 and 2 GHG emissions
  • Limited disclosure of the amount or percentage of assets or business activities vulnerable to or aligned with climate-related risks and opportunities*
  • Qualitative climate-related scenario analysis and anticipated financial effects of climate-related risks or opportunities*#
  • Qualitative disclosure of current financial effects of climate-related risks or opportunities as the effects are not separately identifiable or the level of measurement uncertainty is high
  • Determined the scope of its value chain*
Policies, practices, and performance
  • Minimal description of how to manage material factors
  • One metric per factor
  • Plans for improved reporting in future
Targets
  • Qualitative commitments if no quantitative targets
Sustainability reporting framework
  • GRI
  • ISSB Standards
Board statement
  • Complied

Primary Components

Adoption
Material ESG factors
  • Reviewed factor assessment and updated the material factors
Climate-related disclosures
  • Disclosure of the amount or percentage of assets or business activities vulnerable to or aligned with climate-related risks and opportunities
  • Disclosure of applicable categories of Scope 3 GHG emissions by using secondary data
  • Comparative information in respect of the preceding period
  • Use the greenhouse gas protocol to calculate its GHG emissions
Policies, practices, and performance
  • Specific policies, practices per material factor
  • More quantitative metrics and qualitative description per factor
  • Comparison against previously disclosed commitments with explanations
Targets
  • Short- and long-term qualitative targets and some quantitative targets
Sustainability reporting framework
  • GRI
  • ISSB Standards
Board statement
  • Complied

Primary Components

Adoption
Material ESG factors
  • Reviewed factor assessment and updated the factors
Climate-related disclosures
  • Climate-related scenario analysis with more quantitative outcomes
  • Disclosure of applicable categories of Scope 3 GHG emissions by using primary data
  • More quantitative disclosures of anticipated financial effects of climate-related risks or opportunities
  • Statement of compliance with the ISSB Standards as applicable for climate-related disclosures
Policies, practices, and performance
  • Specific policies, practices per material factor
  • Qualitative and quantitative description per factor
  • Comparison against previously disclosed targets with explanations
Targets
  • Short and long term qualitative and quantitative targets
  • Include peer/sector benchmarks
  • Targets linked to management performance incentives
Sustainability reporting framework
  • GRI
  • ISSB Standards
Board statement
  • Complied

*Using all reasonable and supportable information that is available to the issuer at the reporting date without undue cost or effort.

#Considering the issuer’s skills, capabilities and resources.

Internal Reviews and External Assurance

SGX emphasised the necessity of internal review and external assurance, which could significantly increase stakeholder confidence in the accuracy and reliability of the sustainability information disclosed. The issuer’s sustainability reporting process must be subject to internal review. The issuer may additionally commission an independent external assurance on the sustainability report.

As the internal review shall build on existing governance structures and internal control systems, it should be conducted by the internal audit function, and may involve relevant functions such as risk management, sustainability, or other specialist functions. The review should be conducted in accordance with the International Standards for the Professional Practice of Internal Auditing and should be covered into the internal audit plan over an audit cycle as approved by the Audit Committee of the issuer.

The external assurance by independent professional bodies should be performed in accordance with recognised assurance standards (e.g., ISAE 3000, SSAE 3000, the AA 1000 Assurance Standards or the ISO), and the related information including scope covered, identity of assurer, standard used, and key findings should be disclosed in the report. The assurance may cover different aspects of sustainability disclosures, such as:

  • data and its associated data collection process;
  • narratives;
  • compliance with the specified sustainability reporting framework;
  • process to identify sustainability information reported; and
  • compliance with the Listing Rules
For more detailed information on Consultation Paper, please visit: https://regco.sgx.com/regco/public-consultations/20240307-consultation-paper-sustainability-reporting-enhancing

For large non-listed companies

From FY2027, large non-listed companies (NLCos) (defined as those with annual revenue of at least $1 billion and total assets of at least $500 million) will be required to report and file annual climate-related disclosures. Specific reporting requirements for NLCos will be introduced after the Accounting and Corporate Regulatory Authority reviews the experience of listed issuers and large NLCos.

For more detailed information on NLCos, please visit: https://links.sgx.com/FileOpen/Joint%20Media%20Release%20ACRA-SGX%20RegCo%20on%20Mandatory%20Climate-related%20Disclosure_FINAL.ashx?App=Announcement&FileID=790226

Issuance

Companies should issue their sustainability report once a year. If the sustainability report is contained within the annual report, they should together observe annual report deadlines. If the company issues standalone sustainability report, it should be issued within 4 months of the end of the financial year, or within 5 months of the end of the financial year if external assurance has been conducted.

In either case, the sustainability report should be made available on both SGXNet and the company’s website.

What GreenCo can do for you

Materiality Assessment

We can assist the company in conducting a materiality analysis to determine the most relevant ESG issues for the organisation and stakeholders. Our scientific approach ensures that the material ESG factors identified are objective and useful to the organisation’s long-term sustainability and understand stakeholders’ expectations. We can provide guidance on effective stakeholder engagement practices and incorporate stakeholder feedback and perspectives into the ESG report.

Climate-Related Disclosures

Our expertise and experience in different industries enable us to provide professional support in climate-related disclosures that align with the TCFD recommendations. We are equipped with knowledge of carbon emissions calculation, emissions inventory building (such as Scope 3 GHG emissions) as well as qualitative and quantitative scenario analysis.

Practices and Targets Setting

We provide services to facilitate the company in establishing corporate sustainability policies as well as setting short- and long-term qualitative and quantitative targets that align with the organisation’s values, stakeholder expectations, and performance incentives.

Assurance

While it is noted that there are a lack of globally recognised standards and framework for sustainability reports assurance, we are competent in supporting the company throughout the reporting processes from data collection to report compiling, so as to ensure each step is traceable and ready for external assurance. We can help develop data collection processes, ensure data accuracy and reliability, and verify the accuracy of the reported information. Meanwhile, GreenCo is in partnership with Practising Certified Public Accountant, who can provide assurance service in accordance with ISAE 3000.

Why GreenCo

Considering the level of complication and resources needed to comply with the enhanced sustainability reporting guide from SGX, it is crucial for the companies to fully understand and prepare the sustainability report, particularly those from the most affected industries. As a professional ESG advisory firm, GreenCo has rich experience in assisting different companies in preparing their ESG reports, and has the competent to provide aforementioned services.

We can also support companies in establishing a framework for continuous improvement of ESG practices and reporting, including developing monitoring mechanisms, tracking progress toward goals, and proposing strategies to enhance future ESG reporting.

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