Raymond Cheung
Chartered Actuary · CRO · Board Adviser · Singapore
SGX RegCo's 16 October 2026 queries to Indonesia-based agri issuers on the haze asked whether their own activities contributed. For Singapore boards, environmental incidents are now a continuous disclosure question, not just a sustainability report item.
Some years ago, as a statutory CRO, I sat in a board meeting where an environmental incident at a key supplier was discussed for about four minutes under any other business. The view in the room was that it was the supplier's problem. Six weeks later it was our disclosure problem, our reputation problem and, for a few uncomfortable days, our share price problem. [CONFIRM with Raymond: replace with a real episode if possible]
What SGX RegCo asked
On 16 October 2026, SGX RegCo said it had engaged several Indonesia-based agriculture issuers about the ongoing forest and peatland fires. It asked three things: the impact of the fires on their operations, whether their activities may have contributed to the haze, and how they are responding. RegCo reminded issuers that material information must be disclosed in a timely and transparent manner, and that it expects them to keep stakeholders informed as the situation develops. Several listed agri groups, including First Resources, Golden Agri-Resources and Wilmar International, have set out their fire-prevention measures publicly.
The question that matters is the second one
Impact and response are questions every board expects. Whether your own activities contributed is different. It is a question about causation, asked in real time, under the continuous disclosure rules rather than in the annual sustainability report. A board that cannot answer it within days has an information problem, not a communications problem.
“When the regulator asks whether you caused the problem, the sustainability report is not where the answer gets written.”
This is why I think boards well outside the plantation sector should read the episode closely. It shows how RegCo connects climate and nature risk to the Listing Rules in the moment, not just through the climate reporting cycle. Any company with physical operations or a supply chain in exposed regions could face the same three questions after a flood, a spill or a fire. It is also one more reason the legal view that directors must consider climate-related risk is no longer theoretical.
What I would ask management this week
- Which of our sites and key suppliers sit in areas exposed to fires, floods or other environmental events, and when did we last check?
- If SGX RegCo asked us tomorrow whether our operations contributed to an incident, who would assemble the answer, and how long would it take?
- Does our disclosure committee treat environmental incidents as potentially material, or does it wait for a financial impact to appear?
- Are the commitments in our sustainability report, such as no-burning or no-deforestation policies, backed by monitoring data the board has actually seen?
The companies RegCo engaged will be judged less on the fires themselves than on how quickly and credibly they could explain their own role. That capability is built before the incident, by boards that insist on seeing the monitoring data behind the policy. With enhanced disclosure rules arriving on 1 January 2027, the direction of travel is clear: more disclosure, faster, with the board expected to stand behind it.
Common Questions
What did SGX RegCo ask agri companies about the haze in October 2026?
On 16 October 2026, SGX RegCo said it had engaged several Indonesia-based agriculture issuers about the forest and peatland fires. It asked about the impact on their operations, whether their activities may have contributed to the haze, and how they are responding, and reminded them to disclose material information in a timely and transparent manner.
Is an environmental incident a continuous disclosure matter for SGX-listed companies?
It can be. Under the SGX Listing Rules, issuers must disclose information that is likely to materially affect the price of their securities. An environmental incident that affects operations, creates liability or damages reputation may meet that test, so boards should not assume it can wait for the annual sustainability report.
What should a Singapore board do to prepare for environmental disclosure queries?
Map which sites and key suppliers are exposed to environmental events, make sure the disclosure committee treats such incidents as potentially material, and require monitoring data behind every sustainability commitment. The test is whether management could explain the company's own role in an incident within days, not weeks.
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About the author
Raymond Cheung is a Chartered Actuary, C-suite executive and board adviser with more than 20 years of experience across Asia in risk management, insurance, ESG and corporate governance. He is the CEO of CER Consultancy and an accredited trainer at SMU Academy and the Singapore College of Insurance.