Singapore Exchange Ltd.SGX: S68

2025 SGX Sustainability Report

· Issued by Singapore Exchange Ltd.

Sustainability Report

Singapore Exchange I July 2024 - June 2025

Contents

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  1. A Message from the Board

  2. About the Report

  3. Highlights of FY2025

8 Our Sustainability Approach

9 Sustainability Governance at SGX Group

11 Stakeholder Engagement

13 Materiality Assessment

Material Factors

21 Climate Management

29 SGX Group's Climate Transition Plan

30 SGX Group's Climate Transition Plan Progress

34 Transparent Capital Markets

36 Stewardship of the Financial Ecosystem

39 Sustainability Products and Services

41 Economic Performance

42 Business Continuity

44 Ethics and Compliance

46 Employment Practices and Employment Development

49 Diversity and Inclusivity

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Scan the QR Code to access the

Online Annual Report

or visit investorrelations.sgx.com/financial-information/

annual-reports

Scan the QR Code to access the Online



Sustainability Report, Performance Metrics and Content Index

or visit sgxgroup.com/sustainability/our-sustainability-reports

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‌Progressing Through Volatility A Message from the Board

Opening

The global sustainability landscape in financial year (FY) 2025 has evolved rapidly with increasing volatility and polarised perspectives, policies and regulations, all whilst acute climate risks continue to emerge around the world. Political developments have created challenges for climate action, evidenced by actions like the United States' withdrawal from the Paris Agreement for a second time. Shifting policies are also evident, for example, the European Commission simplifying and consolidating sustainability regulations into the Omnibus package.

COP29 saw the successful execution of the New Collective Quantified Goal on Climate Finance agreement which calls on developed countries to deliver at least US$300 billion per year to developing countries by 2035. This creates the possibility for countries to achieve their climate targets more thoroughly and enhance the resilience of their communities. A key priority for progress is the necessity for ongoing and enhanced collaboration among countries at various stages of development, whether through financial assistance or the provision of innovative solutions and technologies.

Remaining Steadfast As

an International Multi-asset Exchange

Amidst significant economic fluctuations and complex socioeconomic dynamics, SGX Group is positioned as Asia's foremost international multi-asset exchange. We are committed to supporting the advancement of green transition, by addressing the prevailing challenges and seizing the various opportunities presented by the current environment and to continue building on internal and external sustainability capabilities through our four core pillars - SGX Group as a company, business, regulator and in the ecosystem.

As a Listed Company

As a listed company, SGX Group is making good progress in the implementation of our climate transition plan launched in the FY2024 sustainability report. The mandatory adoption of IFRS Foundation's International Financial Reporting Standards Sustainability Disclosure Standards (IFRS SDS) for SGX Group's climate-related disclosures is well underway, in accordance with Singapore Exchange Regulation's

(SGX RegCo) listing rules. We remain committed to maintaining sustainability best practices and credible climate change management. We recognise that decarbonising our operations is a multi-year endeavour that demands commitment across the entire group. In FY2026, we will continue to make progress in our decarbonisation initiatives through cross-team collaboration, ensuring that we stay on course to achieve

our net-zero targets.

As a Business

As a business, SGX Group remains the leading listing venue for international G3 currency Green, Social, Sustainability and Sustainability-linked (GSSS) bonds by APAC issuers, maintaining leading market shares in key markets such as South Korea and the broader ASEAN region. Our focus remains supporting and collaborating with our ecosystem to scale financing and managing the risks of climate transition and we have co-led global workstreams and events related to indices that support the real economy climate transition. In April 2025, we welcomed the listing of the SGX MSCI Emerging Market Climate Action NTR (USD) Index Futures contract. We continue to drive the adoption of our MSCI Climate Action ETFs and futures suite and the FTSE Blossom futures suite, to support clients in incorporating climate considerations into their portfolios.

While the market in these areas

continues to develop, we consistently seek opportunities to collaborate with our industry partners to provide investment options in sustainability products and services.

Material Factors

As a Regulator

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In September 2024, SGX RegCo enhanced its sustainability reporting regime, following a public consultation. Starting from FY2025, all issuers must report Scope 1 and Scope 2 greenhouse gas (GHG) emissions, while incorporating climate-related requirements according to the IFRS SDS. This will ensure issuers' sustainability reports are aligned with global standards.

SGX RegCo has offered relevant capacity building workshops and curated resources to assist corporate preparers in their reporting journeys by highlighting national initiatives like the Sustainability Reporting Grant (SRG). The SRG provides funding support for Singapore-incorporated companies to produce their first IFRS

Glossary

SDS-aligned sustainability report in Singapore before compliance for mandatory climate-related disclosures sets in. SGX RegCo, in partnership with the Institute of Singapore Chartered Accountants (ISCA), developed and published an Illustrative Sustainability Report, providing guidance on integrating Global Reporting Initiative (GRI) Standards and IFRS SDS. This initiative aims to equip issuers with practical skills for meeting enhanced reporting requirements. A series of trainings was also developed following the publication of the Illustrative Sustainability Report, with subsidies on the workshop fees for eligible listed issuers.

In the Ecosystem

SGX Group remains focused on market engagement and strengthening partnerships with global, regional and local sustainability networks, fostering a vibrant and progressive financial ecosystem. In June 2025, we hosted the World Federation of Exchanges' (WFE) Sustainability Conference to facilitate

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meaningful discussions on the diverse roles exchanges play in driving successful transition efforts for regional and global markets. SGX Group is also engaging in further collaboration with peer stock exchanges from Malaysia, Indonesia, the Philippines and Vietnam on the ASEAN-Interconnected Sustainability Ecosystem (ASEAN-ISE) initiative, aspiring to develop a centralised digital infrastructure for

the region, by incorporating various sustainability data points and solutions. We continue to support the Singapore

About the Report

This sustainability report shares our approach to building a sustainable business and ecosystem with consideration of our material factors.

Scope

The report covers the performance of our consolidated entities from 1 July 2024 to 30 June 2025 (FY2025) and is published concurrently with our Annual Report. We have included the historical data for FY2023 and FY2024 for comparison, where available.

Approach to Sustainability Reporting

This Sustainability Report FY2025 is approved by the SGX Group Board of Directors and is prepared in adherence to the prevailing:

  • SGX-Securities Trading (ST) Listing

    Rules 711A and 711B and Practice Note 7.6 Sustainability Reporting Guide (updated January 2025)

  • GRI Standards 2021

  • SASB for Security & Commodity Exchanges governed by the IFRS Foundation

  • Task Force on Climate-Related Financial Disclosures (TCFD) recommendations by the Financial Stability Board (updated October 2021). TCFD has since been disbanded in November 2023 and the monitoring of climate-related disclosures has been transferred to the IFRS from 2024. The IFRS SDS

    Sustainable Finance Association (SSFA) as a Convening Member and active participant in various working groups. SGX Group remains a member of the Glasgow Financial Alliance for Net-Zero (GFANZ) Principals Group, offering directional guidance for the alliance.

    Additionally, we are hosting GFANZ's APAC network central office and serve as a member of its Advisory Board.

    Conclusion

    SGX Group remains steadfast in our commitment to advance sustainability

    are built on the recommendations of TCFD

  • Relevant Sustainable Development Goals (SDGs)

Our FY2025 report is in accordance with GRI Standards 2021 due to its longstanding universal application and robust guidance. In addition, we used Sustainability Accounting Standards Board (SASB) Standards for its industry-based sustainability-related risks and opportunities (SrROs) that have financial impact on the organisation since FY2021 to complement the broader stakeholder focus of the GRI Standards.

In preparation for our eventual adoption of the IFRS SDS, we continue to progress towards the alignment

of our existing reporting and IFRS SDS-aligned reporting in accordance with the prevailing SGX listing rules from FY2026. IFRS SDS provides a comprehensive set of sustainability disclosures tailored to meet the needs of investors.

The approach for reporting boundaries used in our Financial Statements is also used to consolidate sustainability information and is consistently applied across our reporting boundaries and across material topics. We have

also aligned the preparation of our Sustainability Report with the

initiatives. Our long-standing efforts have enabled us to lead, futureproof and strategically develop our sustainability framework, while contributing to local, regional and global sustainability goals. Looking ahead, we will continue to

Material Factors

advance our climate transition implementation to futureproof SGX Group, while fostering innovation, engaging with stakeholders and driving transformative change, to ensure a more resilient and sustainable future.

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preparation of the financial statements, by consolidating and reporting via the same entities, within a common reporting period from FY2025 onwards aligned with IFRS SDS.

The GRI, SASB and TCFD content index as well as our performance metrics are an integral part of the sustainability report and can be found at the end of this report and at the SGX Group website.

In line with our sustainability efforts, our Sustainability Report will be published online instead of in print media. This report should be read together with our Annual Report FY2025.

Glossary

We welcome feedback on this report and any aspect of our sustainability

performance. Comments or feedback can be sent to sustainability@sgx.com



SGX Group Annual Report

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Review and Assurance

The independent external assurance by KPMG LLP, including the scope of work and conclusions which have been externally verified, can be found at the end of this report.

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Highlights of FY2025

Material Factors

Driving adoption of indices supporting real-economy decarbonisation SGX Group CEO was the co-chair of the GFANZ Index Investing workstream, which launched a public consultation in October 2024 on voluntary guidance on the development of "transition-informed" indices to support the global transition to net-zero - titled "Index Guidance to Support Real-Economy Decarbonisation". SGX Group co-led the GFANZ Index Investing roundtable during New York Climate Week 2024, an index investing roundtable during

Principles for Responsible Investment (PRI) in Person 2024 in Toronto and a PRI roundtable on index investing during London Climate Action Week 2025. Whilst GFANZ has formally concluded the work on Index Investing, all of these efforts aim to help drive adoption of the indices to aid the global transition to net-zero.

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Scientific Beta named "Best ESG Index Provider" at the ESG Investing Awards 2025

The award recognised Scientific Beta's robust approach to sustainable investment strategies and its work on the Climate Transition Risk Beta, a market-based risk metric developed in-house. The approach overcomes the traditional shortcomings associated with backward-looking carbon emissions data, by utilising market prices to reflect up-to-date market consensus on companies' perceived exposure to climate transition risks. The Climate Transition Risk Beta is forward-looking and reflects climate-related information deemed to be material by investors.

Growing adoption of SGX MSCI Climate Action Indexes and the launch of SGX MSCI Emerging Market Climate Action NTR (USD) Index Futures SGX launched the MSCI Emerging Market Climate Action NTR (USD) Index

Glossary

Futures, adding to its five equity derivative contracts tracking MSCI Climate Action indexes. The contract references the MSCI Emerging Market Climate Action Index NET USD index, addressing growing interest in emerging markets and climate action investment strategies. These futures, together with the range of globally listed ETFs and the Climate Action indexes help institutional investors target climate transition and support companies' emissions reduction efforts. The full range of MSCI Climate Action index products continues to grow from strength to strength with the AUM of the iShares MSCI Asia Ex-Japan Climate Action ETF tripling since launch.

GFANZ APAC Summit 2025

GFANZ Asia Pacific (APAC) Network hosted by SGX Group, held its annual GFANZ APAC Summit. The Summit gathered leaders from finance, business, government and civil society with discussions on topics including transition planning and financing the coal to clean transition in Asia Pacific. The 10th GFANZ APAC Advisory Board meeting was held as part of the summit.

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Highlights of FY2025

SGX RegCo to start incorporating IFRS SDS into climate reporting rules and the launch of an Illustrative Sustainability Report

Material Factors

SGX RegCo has enhanced its sustainability reporting regime and will start incorporating the latest international standards into its sustainability reporting regime. Beginning with FY2025, SGX RegCo will require all issuers to start reporting Scope 1 and Scope 2 GHG emissions. Their climate-related disclosures must also start incorporating the climate-related requirements in the IFRS SDS.

An Illustrative Sustainability Report based on the GRI Standards and the IFRS SDS, was published by ISCA with the support of SGX RegCo. It aims to offer corporate preparers with practical guidance by illustrating how an entity might apply the climate-related requirements under the IFRS SDS' IFRS S1 and IFRS S2, concurrently with the GRI Standards.

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International Women's Day

SGX Group celebrated International Women's Day and participated in WFE's 11th Annual "Ring the Bell for Gender Equality". Supported by exchanges worldwide, the initiative aims to foster greater gender equality and empower women in all spheres - across workplaces, marketplaces and communities. In honour of the celebration and reaffirmation, our partners, Women Venture Asia, International Finance Corporation & YPO Singapore Integrated, joined us in the striking of the gong to mark the beginning of the trading day.

Singapore Green Steel Forum

Glossary

SGX Group's Head of Global Sales and Origination opened the forum with a speech that reiterated the crucial need for sustainable transformation in the steel industry. SGX Commodities' comprehensive derivatives suite continues to empower risk management strategies while enabling price discovery for critical commodities across the steel value chain.

WFE's Sustainability Conference

SGX Group hosted the WFE's second Sustainability Conference, bringing together exchanges from around the globe to discuss the critical need for internal transition planning. The event emphasised the pivotal roles these exchanges play in supporting transition efforts within financial markets. SGX Group shared valuable insights from the challenges encountered while developing its inaugural transition plan, followed by an engaging panel discussion.

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‌Progressing Through Volatility Our Sustainability Approach

As a leading multi-asset exchange, SGX Group supports our partners, companies, investors and other stakeholders in their sustainability journeys, while adapting to meet the evolving expectations and increasing demands of the market within the changing sustainability and economic landscape.

Our Sustainability Vision

Material Factors

We continued the implementation of our Sustainability Vision, to be a leading sustainable and credible transition finance and trading hub. Our progress is best viewed through the lens of SGX Group's four core pillars - as a company, business, regulator and in the ecosystem.

Our Core Pillars Enabling Actions Objectives

As a company



As a business



As a regulator



In the ecosystem

  • Foster responsible business practices

  • Demonstrative leadership in sustainability and credible climate change management, including the execution of our climate transition plan

  • Develop a suite of sustainable and credible transition financing products, services and solutions and promote greater product adoption

  • Leverage on SGX Group's multi-asset exchange platform for investors

    and issuers

  • Guide the market on sustainability, including climate-related disclosures

  • Provide capacity development

  • Be a positive influence and foster collaboration and partnerships

  • Provide data, tools, resources and connect stakeholders to drive industry discussions

  • Conduct business with integrity and cultivate trust

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  • Support climate action among SGX Group listed corporations

  • Support the development of a green and resilient economy and financial ecosystem

  • Venue of choice for transition capital and trading

  • Foster best practices in sustainability-related information disclosures

  • Facilitate availability of decision-relevant sustainability-related information in the market

    Glossary

  • Support stakeholders' ambition in achieving sustainability objectives

  • Effective sustainability strategy implementation



    Sustainability Vision

    Scan the code or visit

    sgxgroup.com/sustainability

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‌Progressing Through Volatility Sustainability Governance at SGX Group

SGX Group Board is collectively responsible for the long-term sustainable success of SGX Group. The Board has delegated the Executive Management Committee (EMCO) the authority to approve matters arising from the day-to-day operations across the value chain of SGX Group within the limits and policies approved by the Board.

Recognising the importance of having Board oversight on sustainability-related matters, including climate risks and opportunities, various steps have been taken to engage the board, many of which have been integrated into our existing Board engagement processes. Sustainability is now discussed with the Board as: (1) an annual strategy discussion on sustainability and sustainable finance, with year by year assessment either by meeting or circulation, (2) an annual review of SGX Group's three year plan, business unit strategies and capital plan, (3) an annual review on risk appetite and key risks, (4) an annual review and approval of the sustainability report, (5) an annual review of achievements of strategic and non-financial priorities, (6) Board engagement on selected topics such as decarbonisation and scenario

analysis with sub-committees e.g. the risk management committee and (7) review of SGX Group's progress on integration of climate reporting between the sustainability report and financial statements.

To ensure the Board is adequately skilled to oversee sustainability-related matters, SGX Group's Board Diversity Policy endorses the principle that the Board should possess a balanced mix of skills, knowledge, experience and other diversity aspects. All the members of the

board have undergone sustainability training course organised by Singapore Institute of Directors (SID). For more information related to the Board's duties, please refer to the Corporate Governance report on page 50 oF our Annual Report.

In FY2025, we enhanced SGX Group's climate and sustainability-related goals and their linkage with our performance and remuneration framework. Our Remuneration Report can be found on page 80

oF our Annual Report. We will continuously review and enhance our governance structure, policies and procedures to ensure ongoing accountability and oversight of SGX

Group's commitment to our transition and sustainability journey.

Driving Sustainability Strategy

Material Factors

A robust governance structure is foundational in driving our climate and sustainability strategy and actions and in SGX Group these include dedicated roles and responsibilities by our Board of Directors, Risk Management Committee, Audit Committee and EMCO. The Sustainability Steering Committee discusses and decides the implementation of our key climate

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and sustainability strategies. The Sustainability and Sustainable Finance team drives and supports our strategic vision, direction and implementation. SGX RegCo Sustainable Development Office drives our regulatory efforts on sustainability, including climate-related disclosures, market engagement and education. In alignment with SGX Group's sustainability goals, we urge our suppliers to implement sustainable practices. Selected vendors are required to participate in the SGX Sustainability Vendor Survey and must attest that their policies and practices are consistent with sustainable standards.

Glossary

SGX Group's climate transition plan has been prepared by the Sustainability and Sustainable Finance team in consultation with the relevant units, Sustainability

Steering Committee and is approved by EMCO and the Board.

Sustainability Governance Structure

Board of Directors ▪ Oversees SGX Group's approach to sustainability and the integration of sustainability-related matters, including climate-related risks and opportunities, in the formulation of our

long-term strategy

    • Monitors and oversees progress on sustainability and climate-related risks and opportunities that meets shareholder expectations and reviews significant issues raised

      Risk Management Committee (RMC)

  • Comprising Board Members, oversees SGX Group's key risks and risk appetite

  • Monitors and oversees sustainability-related risks which include climate risk

    Audit Committee (AC) ▪ Comprising Board Members, assists the Board in discharging its statutory and other responsibilities related to the integrity of the financial statements, monitoring of the system of internal controls and independence of the external auditor including for sustainability reporting assurance

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Executive Management Committee (EMCO)

Sustainability Steering Committee

(SSC)

Cross Business Units Sustainable Finance Meetings

  • Chaired by the CEO and comprises senior leadership across the organisation

  • Reviews, evaluates and approves key sustainability approach, risk management policies and practices, sets targets and measures performance against the targets

  • Chaired by Head of Sustainability and Sustainable Finance, sponsored by the CEO and comprises relevant EMCO members and senior executives from across the units

    Material Factors

  • Discusses and decides key implementation of SGX Group's sustainability strategy, including our climate agenda and climate risk management and makes decisions or advises the EMCO on material sustainability-related matters through regular SSC Meetings

  • Sponsored by the CEO, led by the Sustainability & Sustainable Finance team and comprises relevant senior executives from across the business units

  • Focuses on growing the revenue of green and sustainability products that contributes to SGX Group's business resilience, as well as futureproofing our existing businesses

Sustainability-focused Team

SGX Group Sustainability & Sustainable Finance (SSF)

SGX RegCo Sustainable Development Office (SDO)

  • Established in February 2021

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  • Drives and supports the strategic vision, direction and implementation of SGX Group's sustainability ambitions and further broadens and deepens its sustainable finance pillars

  • Supports sustainability practices within SGX Group and participates in selective external sustainability taskforces on a local, regional and global basis

  • Provides technical expertise and specialised knowledge, collaborates with the relevant units

    across SGX Group on sustainability efforts internally and externally, including:

    • Working with the Business Units for sustainable products and services development

    • Working with industry peers and networks to embed best practices into SGX Group

      across the units and contribute to ecosystem efforts

    • Being responsible for SGX Group's sustainability reporting together with the Finance & Corporate Development unit and working with all relevant units on IFRS SDS

      reporting readiness

    • Working closely with the SGX RegCo Sustainable Development Office as necessary

  • Established in January 2023

    Glossary

  • Drives regulatory efforts on sustainability, including:

    • Advancing the availability of corporate sustainability disclosures by listed equity issuers

    • Participating in global and industry-wide standards-setting projects on corporate

      sustainability disclosures and products

    • Implementing initiatives to advance the sustainability performance of listed equity issuers

    • Building awareness and capability within the ecosystem

      Sustainability Risk Management SGX Group recognises that effective risk management is integral to SGX Group's business strategy and sustainability journey and that sustainability risks, including climate-related risks and opportunities and the impacts, are inherently linked to other strategic, financial and operational risks. Hence,

      these are managed in a consistent manner according to our Enterprise Risk Management (ERM) framework, with the Business Units and relevant Operating Units owning and managing the risks. SGX as a company has identified climate-related risks and opportunities as an emerging key risk in our Risk Management Report. In

      accordance with our ERM framework, key risks are assessed using an impact-likelihood matrix to drive risk prioritisation and

      performance updates are monitored and reported to the Management and Board. Please refer to pages 35 to 39 oF our Annual Report Risk Management for more details.

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‌Progressing Through Volatility Stakeholder Engagement

Stakeholder engagement is an integral part of SGX Group as an exchange and as a regulator. We adopt an inclusive and transparent approach that balances the needs and interests of material stakeholders to ensure our long-term sustainability. Our stakeholders provide valuable insights and diverse perspectives that contribute to decision-making, innovation, risk mitigation and trust-building. At the same time, we are continuously communicating key information to our stakeholders through various platforms and channels on a regular and ad hoc basis throughout the year.

Material Factors

The following stakeholder groups have been identified as intrinsic to SGX Group and as part of our natural touchpoints in our business and the wider ecosystem.

Key Stakeholders Engagement Methods Interests and Concerns

Employees ▪ Town halls, huddles, focus group discussions, employee surveys, workshops, trainings and seminars, corporate events, Group Leadership Teams forums, CEO Blog, internal staff communication platforms, Chairman luncheons, "Ask Me Anything" sessions with the CEO and EMCO, CEO lunch with new hires, CEO engagement with interns, SGX Cares CSR engagement activities, Long Service Awards ceremony, staff appreciation event

Regulators and Government ▪ Dialogues, surveys, feedback sessions and jointly organised events

  • Collaboration with industry bodies and taskforces to build up technical knowledge and best practices

    Issuers ▪ Direct engagements to provide updates, invitations to provide feedback on initiatives, cross-selling of SGX Group's multi-asset products and services, participate in training sessions, networking and related events

  • Guidance through regulatory announcements and regulator's columns

  • Sustainable finance-related associations, taskforces and memberships

Intermediaries ▪ Direct engagements to provide updates, invitations to provide feedback on initiatives, offers to participate in training sessions, networking and related events

Investors and Research Analysts ▪ Management briefings, non-deal investor

roadshows, investor conferences, corporate access and annual general meeting

  • Platforms to engage staff across SGX Group and to keep them updated on all the latest developments across the business and to promote collaboration across the organisation through engagement activities

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  • Market structure developments

  • Corporate governance

  • Regulatory policies and practices

  • Listing policies and practices

  • Growing liquidity and market capitalisation

  • Access to investors

  • Capital raising, risk and cost management

    Glossary

  • Sustainability-related issues

  • Infrastructure developments and business continuity planning

  • Regulatory policies and practices

  • Distribution of products and services

  • Financial performance

  • Corporate strategy and growth initiatives

  • Capital management and allocation

  • Environmental, social and governance practices

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Key Stakeholders Engagement Methods Interests and Concerns

Investment Community ▪ SGX Group Integrated Stakeholder Study

  • Financial literacy and advocacy programmes with partners

  • Large-scale retail investor education events locally and regionally

  • Thematic investor education events

  • Social media and investment forums

  • Investment-related research content and analyst reports

  • Sustainable finance-related associations, taskforces and memberships

    Public and Communities ▪ SGX Future in Reshaping Sustainability Together (FIRST) platform

  • SGListCos

  • Publicly available conferences and speaking engagements

  • Financial literacy/management and investing knowledge to navigate market conditions

  • Retail investing preferences

  • Increasing investment returns

  • Market developments and investment strategies

    Material Factors

  • Sustainable investing

  • Market structure developments and corporate governance policies

  • Academic learning opportunities

  • Corporate social responsibility activities

    Suppliers, Vendors and Service Providers

  • Business review meetings ▪ Innovative products and services that

    address our current and future needs

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    • Operational excellence

    • Business continuity

Internal Capacity Building

SGX Group's commitment and strategic intent is to build a resilient business based on placing sustainability at the core of what we do. In addition to mandatory training on topics such as ethics, compliance and risk, we are equipping staff with the knowledge and competencies on sustainability and climate-related content to

make informed decisions and take responsible actions regarding our business, products and policies.

Our sustainability and sustainable finance (including climate-related) curriculum framework combines foundational e-learning modules,

in-person structured courses and professional development qualifications. In FY2025, we launched a specially curated in-person sustainability training for SGX Group colleagues on the application of sustainability (including climate-related) in functional roles within SGX Group.

The workshop is aimed at empowering employees with a good understanding and application of sustainability within the SGX framework, recognise how their job scope may evolve in response to emerging sustainability trends and apply the Sustainable Finance Job Transformation Map (JTM) study, to remain relevant and effectively implement sustainability within the

context of SGX Group. The JTM study was developed by the Monetary Authority of Singapore (MAS), in collaboration with the Institute of Banking and Finance and supported by Workforce Singapore. This

strategic framework details how sustainability trends are transforming

job roles within Singapore's financial services sector.

"SGX Group's commitment and strategic intent is to build a resilient business based on placing sustainability at the core of what we do."

Glossary

SGX Group colleagues participated in industry-level capacity development initiatives, such as the SGX-GRI Sustainability Reporting Learning Series and the SGX-ISCA training on sustainability reporting - applying the IFRS SDS, which were targeted at our listed companies and market participants. Our colleagues can also access on-demand online training resources on our website such as the introductory e-learning course, which is a compilation of online educational videos aimed at providing a foundational understanding of sustainability (including climate) reporting. Other initiatives include conducting new director induction sessions on SGX Group's climate and

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sustainability commitments and transition plan, as well as an in-house workshop on SGX Group's GHG emissions profile for staff training purposes. An important component involves on-the-job learning and training opportunities, which are occurring

as we increasingly integrate climate considerations into our business processes and operations, such as those related to data centre area and product innovation and strategy. In FY2025,

2,197 hours of sustainability (including climate) training were recorded, with over 280 cumulative attendances in in-person sessions or e-learning modules.

External Capacity Building SGX Group offers ongoing capacity-building programs and activities for

external stakeholders and the public. For more information on our external capacity building efforts, please refer

to the section on Stewardship of the Financial Ecosystem in this report page 36 and Corporate Social Responsibility - SGX Cares Financial Literacy of our Annual Report page 46.



Material Factors

Capacity Building

Scan the code or visit sgx.com/sustainable-finance/capacity-building-training

Materiality Assessment

Our Materiality Assessment Process

The IFRS SDS provides a consistent sustainability disclosure framework that encourages transparency and comparability for companies and investors globally. In preparation for the IFRS SDS for sustainability reporting, we conducted reviews on our overall reporting regime. In FY2024, we conducted an external

stakeholder engagement assessment with our key external stakeholders

- regulator, issuers, intermediaries, investors, research analysts, rating agencies, investment communities, suppliers and associations to review our existing sustainability materiality assessment. This involved examining

our sustainability material factors through the double materiality approach to ensure a holistic view from a financial ("outside-in") lens, an impact ("inside-out") lens or both. We consider that our material factors from the previous year continue to be relevant in FY2025. As both an exchange and regulator, we acknowledge that our influence extends beyond our organisational boundaries. Consequently, our material factors encompass the priorities and initiatives of SGX Group as well

as the broader ecosystem.

Integrating Sustainability into Strategy

Our efforts to lead, futureproof and build across our nine material factors are

guided by the strategic roles across our four core pillars - as a company, business, regulator and in the ecosystem. Our reporting approach plays a crucial role in risk management, performance measurement, decision-making

Glossary

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and strategy formulation. Through these core pillars, sustainability is incorporated into the organisational functions, operations and culture. Collectively, the impact of these material factors enables SGX Group to achieve the following: (1) building a sustainable business, (2) empowering the community and growing the ecosystem, (3) advancing the global climate transition and (4) transparency and accountability.

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Our Material Factors



  • Climate management

  • Transparent capital markets

  • Stewardship of the financial ecosystem

  • Sustainability products and services

  • Economic performance

  • Business continuity

  • Ethics and compliance

  • Employment practices and employee development

  • Diversity and inclusivity

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Our Climate Transition Plan and Relevant Material Factors

Material Factors

Building upon the analysis of climate-related risks and opportunities, SGX Group's climate transition plan demonstrates our commitment, efforts and actions to support the transition of our company, business and ecosystem to a low-carbon and resilient future. The transition plan covers three of our core material factors, namely climate management, sustainability products and services and stewardship of the financial ecosystem. It is an integral component for incorporating sustainability, including climate factors, into our overall strategy and implementation. Our transition plan was first published last year and details of our targets, priorities and strategy can be found on pages 25 to 33 oF our FY2024 Sustainability Report. Our progress has been updated and detailed on pages 30 to 33 of this report.



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Relevant Material Factors

Foundation
  • Climate management

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  • Sustainability products and services

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  • Stewardship of the financial ecosystem

"Building upon the analysis of climate-related risks and opportunities,

SGX Group's climate transition plan demonstrates our commitment, efforts and actions to support the transition of our company, business and ecosystem to a low-carbon and resilient future."

Glossary

Sustainable Development Goals The SDGs outline 17 interconnected goals that highlight the integration

of environmental, social and economic dimensions of sustainable development. Achieving these goals

requires widespread ownership and commitment from stakeholders across various sectors. Below, we

have broadly mapped how our nine material factors align with the respective SDGs.

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Key Highlights of Our Performance and Targets

When disclosing SGX Group's targets and commitments of our material factors, we consider the nature of each material factor and its impact on our operations, stakeholders and long-term financial performance.

When targets are specific and time-bound, we include them as short-, mid- and long-term. Where goals and objectives are characterised to continue without a fixed end date and are part of our long-term vision and core values, we define them as commitments.

Material Factors

Please refer to the following pages for more information on the respective material factors.

Material Factors Definitions, Impacts Our Performance

and SDGs and Examples in FY2025

Targets and Commitments

Progress

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Climate management





Efforts to address our operational emissions, align relevant platforms and products, and

engage our ecosystem towards net-zero target by 2050 to limit global temperature rise to

Glossary

1.5°C in line with the Paris Agreement and publish our actions through a climate transition plan

  • Disclosed absolute emissions and emission intensity for Scope 1, 2 and 3 in line

    with GHG Protocol Standards

  • Reduced Scope 2 emissions in line with our decarbonisation pathway primarily through data centre optimisation, complemented by the procurement of renewable energy certificates (RECs)

    for our Singapore-based operations1

  • Completed review and disclosed all relevant Scope 3 emission categories

  • The review of our emissions reduction targets against expected revised Science Based Targets initiative (SBTi) Corporate Net-Zero Standard

    2.0 could not commence as the revised standard was not yet finalised at the end of FY2025

  • Over 2,197 hours and 280 cumulative attendance of climate-related training for staff recorded

    Short (next 12 months) and Interim (between now and 2030):

  • Continue to disclose Scope 1, 2 and 3 emissions

  • Remain on track to reduce Scope 2 absolute carbon emissions by 42% by FY2031 from FY2021 baseline2

  • Our Scope 3 emissions target on engaging our data centre supplier to set science-based targets has already been achieved as of FY2022

  • We aim to optimise the energy efficiency and emissions profile of our data centres

  • A comprehensive review of our emissions reduction targets is planned to align with the prevailing leading GHG target setting framework, such as the SBTi Corporate Net-Zero Standard 2.0 expected to be issued at the end of 2025 or later or the ISO Net-Zero Standards3 which is also in the process of being created

  • Submit revised targets to SBTi for validation where applicable

  • Continue to make available climate-related training for staff

    Long-term (by 2050):

  • To reach net-zero emissions by 2050

    On track

    1 We intend to reduce Scope 2 emissions through an agreement for the purchase and retirement of 1,200 Singapore RECs, which is expected to correspond to a reduction of 494 tCO2e. At the time of disclosure, the RECs have been procured but will only be delivered by 31 August 2025 based on the procurement agreement.

    2 GHG targets stated are all gross targets.

    3 The ISO Net-Zero Standards builds on the ISO Net-Zero Guidelines (IWA 42:2022): The international standard on net-zero will give the public greater confidence and guard against greenwashing by setting out robust guidance and requirements offering the potential to verify the credibility of claims.

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Material Factors Definitions, Impacts Our Performance

and SDGs and Examples in FY2025

Targets and Commitments

Progress

Transparent capital markets





Stewardship of the financial ecosystem





Zero tolerance policy for incidents that jeopardise the operation of a fair, orderly and efficient marketplace

Uphold high standards of disclosure and transparency to

build trust across stakeholders, promoting a liquid market and sustaining long-term capital market growth

Implementation of SGX-ST sustainability reporting rules

Efforts to advance the adoption of globally recognised sustainability and climate-related guidelines and frameworks, through partnerships and fostering an educated ecosystem and supporting the global transition journey

  • Disclosed corporate disclosure policy

  • Disclosed number of voluntary trading halts due to public release of information and market volatility

  • Disclosed involvement in automated trading and associated risks and opportunities

  • Disclosed percentage of trades generated from automated trading system

  • Enhanced the sustainability reporting regime with the incorporation of the IFRS SDS in respect of climate-related disclosures

    Glossary

  • Continued facilitating compliance with the sustainability reporting requirements for our listed companies by offering relevant capacity building workshops and resources, and providing targeted support by adopting a data-driven approach

  • Continue to disclose policies relating to alerts and disclosure of material information of listed companies

  • Continue to disclose number of voluntary trading halts and number of halts due to market volatility

  • Continue to encourage disclosure of sustainability information by listed companies

  • Continue proactive engagement with stakeholders, including market participants, partners, policy makers and standard setters

  • Implement initiatives including provision of training, awareness activities and guidance to encourage market participants to advance their sustainability journey

  • Promote climate-related disclosures, particularly for listed companies and offer climate disclosure training at least annually

    Achieved and on track

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    Material Factors

    On track

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Material Factors Definitions, Impacts Our Performance

and SDGs and Examples in FY2025

Targets and Commitments

Progress

Sustainability products and services





Economic performance



Building a sustainable business by supporting adoption of sustainability-related product shelf, contributing to business resilience

Revenue and other indicators of business growth which contribute to the wider economy by creation of jobs and delivering value to our stakeholders

  • The performance of our six listed sustainability-themed ETFs, with a total Assets Under Management (AUM) of $2.2 billion, has increased by 133% year-on-year

  • This growth was primarily driven by significant gains in the iShares MSCI Asia Ex Japan Climate Action ETF, with its AUM increasing

    by $1.2 billion - largely attributed to investments from the Finnish pension fund, Ilmarinen

  • Scientific Beta introduced a new climate change screen in FY2025 and was named the industry's Best ESG Index Provider at the ESG Investing Awards 2025

  • Launch of SGX MSCI Emerging Market Climate Action futures contract expanded the existing SGX's shelf of derivatives tracking MSCI Climate Action Indexes Net USD

  • GFANZ index investing workstream (co-chaired by L&G Asset Management, PKA and SGX Group) concluded a public consultation on its draft guidance in Q1 FY2025 on the development of "transition-informed" indices to support the global transition to

    net-zero

  • Disclosed the group's financial statement in accordance with the accepted financial reporting standards

  • Continue to promote adoption and momentum on the existing suite of climate

    and sustainability-focused products, solutions

    and platforms

  • Continue to collaborate with ecosystem partners to explore and launch, where appropriate, new products

    and solutions that incorporate climate and sustainability considerations

  • Continue to disclose the group's financial statement in accordance with the accepted financial reporting standards

    On track

    Glossary

    Independent Limited Assurance Report

    Material Factors

    Achieved and on track

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Material Factors Definitions, Impacts Our Performance

and SDGs and Examples in FY2025

Targets and Commitments

Progress

Business continuity





Ethics and compliance



Employment practices and employee development



Robust and well-tested recovery plans to ensure operational resilience and maintain high levels of trust from market participants

Prevention of technology errors and market disruptions

Efforts to combat corruption, comply with tax and relevant regulations and manage conflicts

Maintain SGX Group and the broader capital market infrastructure as fair, orderly and transparent

markets and safe and efficient clearing houses

Employment practices to retain talent and ensure the health, safety and well-being of our staff and employee development

  • Zero significant market disruptions or downtime

  • Zero material data breaches

  • Disclosed efforts to prevent technology errors,

    security breaches and market disruptions

  • Disclosed the key principles of our Code of Conduct and Tax Policy

  • Zero cases of bribery, corruption, anti-competitive behaviour or other material non-compliance with the law

  • Zero monetary losses as a result of legal proceedings arising from relevant financial industry laws or regulations

  • Disclosed processes for identifying and assessing conflicts of interest, including key principles of Code of Conduct and Regulatory Conflicts Governance Framework

  • Average training hours per employee at 49 hours for SGX and 42 hours for SGX Group

  • Launched additional modules for our in-person sustainability programme

  • Implemented in-person workshops on emerging key market trends such as generative AI

  • Continue to set high standards and maintain vigilance in operational and technological risk management to prevent errors, security breaches and market disruptions

  • Continue business continuity exercises across multiple domains, with relevant internal stakeholders and industry-wide participants

  • Achieve mandatory information security training for all applicable staff

  • Maintain zero cases of material non-compliance with laws

  • Disclose number of material non-compliance with laws

  • Disclose number of incidents of corruption and

    actions taken

  • Achieve mandatory ethics and compliance training for all applicable staff

  • Achieve 40 average

    training hours per employee for SGX Group

  • Implement programmes for upgrading employee skills and transition assistance programmes for the purpose of incorporating sustainability and climate knowledge into their scope of work

    Achieved and on track

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    Material Factors

    Achieved and on track

    Glossary

    On track

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Material Factors Definitions, Impacts Our Performance

and SDGs and Examples in FY2025

Targets and Commitments

Progress

Material Factors

Diversity and inclusivity







Embracement of diversity amongst our staff, any discrimination based on gender, age or other socio-cultural factors is prohibited, maintaining an inclusive work environment

  • Appointed one female director, Datuk Maimoonah Hussain onto the SGX Board at the AGM in 2024, bringing female directors representation to approximately 41% (5 out of

    12 directors). Her appointment will contribute significantly

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    to the diversity of skillsets, geographical experience and bolster the financial services/ capital markets experience on the SGX Board

  • Continue to ensure diversity to achieve the strategic and business objectives of SGX

  • Where external search consultants are used to search for candidates for Board appointments, the brief will include a requirement to present female candidates

  • Since FY2023, SGX Group has reached its target goal of achieving 30% representation of female directors on the SGX Board. Notwithstanding this, the Nominating and Governance Committee will continue as part of its Board succession planning, to identify and evaluate suitable candidates to maintain diversity, including gender diversity, on the SGX Board

    Glossary

  • Achieve mandatory training on preventing discrimination and harassment for all applicable staff

On track

‌Material

Factors

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‌Material Factors Climate Management

Material Factors

Efforts to address our operational emissions, align relevant platforms and products, as well as to engage our ecosystem towards the target of net-zero by 2050 to limit global temperature rise to 1.5°C in line with the Paris Agreement and publish our actions through a climate transition plan.

SGX Group's Approach to Climate Management

The World Economic Forum's Global Risk Report 2025 reaffirms that extreme weather events remain the top long-term global risk (10-year horizon) for the second consecutive year-a position it first held in 2014. Climate and environmental risks also feature prominently in the near term, accounting for two of the top ten risks over the next two years and four of the top five long-term risks.

Misinformation and disinformation

Extreme weather events

State-based armed conflict

Societal polarisation

Cyber espionage and warfare

Pollution

Inequality

Involuntary migration or displacement

Geoeconomic confrontation

Erosion of human rights and/or civic freedoms

Extreme weather events

Biodiversity loss and ecosystem collapse

Critical change to Earth sytems

Natural resource shortages

Misinformation and disinformation

Adverse outcomes of AI technologies

Inequality

Societal polarisation

Cyber espionage and warfare

Pollution

Risk categories Economic Environmental Geopolitical

Societal

Technological

2 years

1st 2nd 3rd 4th 5th 6th 7th 8th 9th

10th

10 years

1st 2nd 3rd 4th 5th 6th 7th 8th 9th 10th

Independent Limited Assurance Report

Source: World Economic Forum Global Risks Perception Survey 2024-2025

The 2025 report marks the 20th edition of the global risk survey and while the perceived risks posed by other economic, geopolitical, societal and technological issues have shifted over time, climate and environmental risks have consistently topped

10-year risk rank

Glossary

the 10-year rankings.

1

2

10

15

20

24

2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025

Year

Extreme weather events (floods, heatwaves, etc)

Source: World Economic Forum Global Risks Perception Survey 2024-2025

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‌Material Factors

The Paris Agreement forms the foundation of global efforts to combat climate change. Multilateral climate policy necessitates international cooperation to deliver progress on climate action. The United States' withdrawal from the Paris Agreement, along with reduced financial support to other countries' climate change mitigation and adaptation efforts, has impacted global initiatives on climate change. The latest Intergovernmental Panel on Climate Change (IPCC) synthesis report for the Sixth Assessment Report states that current actions may be inadequate despite an increase in policies and regulations on climate mitigation before the United States' withdrawal. It also indicates that physical and transition risks are anticipated to rise in the future.

Singapore's Third National Climate Change Study, conducted by the Meteorological Service Singapore's Centre for Climate Research Singapore, has determined that the trend of increasing heatwaves and rainfall is anticipated to continue in Southeast Asia, in alignment with findings from the sixth IPCC report. Both daytime and nighttime temperatures are expected to rise, leading to increased pressure on the electricity grid due to higher demand for cooling energy.

Singapore's annual mean temperatures are projected to rise by between 0.6 and 5 degrees Celsius by the end of this century, with projections of 41 to 351 very hot days per year (daily maximum temperature exceeding 35 degrees Celsius) as compared to an average of 21.4 days per year in the past 40 years. Monsoon rains are also expected to be more intense, leading to a heightened risk of flash floods.

In 2024, Singapore's annual average temperature was 28.4 degrees Celsius, making it the warmest year on record (tied with 2019 and 2016).

In the face of increasing climate threats, SGX Group understands the importance

of developing a strong strategy and risk management framework that sets the foundation for SGX Group's climate resilience.

To aid our stakeholders' understanding of our climate resilience efforts, SGX Group has been a supporter of the TCFD since 2016, including as a vice-chair of TCFD. TCFD recommendations defined categories for climate-related risks and opportunities, creating a standardised common framework for consistent assessment, analysis and reporting of such matters. These are divided into two major categories: (1) risks and opportunities related to the transition to a lower-carbon economy and (2) risks related to the physical impacts of climate change. For details of SGX Group's approach to the TCFD recommended disclosures, please

refer to our TCFD Content Index.

The IFRS SDS builds on the recommendations of TCFD and has taken over from TCFD in the monitoring of progress on climate-related disclosures. The IFRS SDS

recommendations encompass four main elements: (1) Governance, (2) Strategy,

(3) Risks Management and (4) Metrics and Targets. These elements are also integral to transition planning and align with the four overarching components of the TCFD. In preparation for the adoption of the IFRS SDS from FY2026, we have begun to progressively disclose information in accordance with the IFRS SDS framework starting in FY2025.

Understanding Our Climate Risks We explored climate-related risks and opportunities across three timeframes: short-term (1 to 3 years), medium-term

(3 to 10 years) and long-term (10 years and beyond). These timeframes largely align with the strategic planning horizons of SGX Group. This assessment was guided and supplemented

by climate scenario analysis, as recommended by the TCFD and IFRS SDS on climate-related disclosures, to

understand how our business resilience might be impacted through hypothetical climate scenarios. These risks have been reviewed and updated in response to developments in the past financial year.

Material Factors

Climate Scenario Analysis

Climate scenario analysis is a framework that allows companies to assess the potential impacts of hypothetical climate scenarios on their business resilience.

These scenarios are not predictions; instead, they illustrate possible future states of the world based on specific trends or conditions.

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We began performing climate scenario analysis in FY2023 and have continued to progressively enhance our climate scenario analysis capabilities in FY2024 and FY2025 with enhancements to our climate scenario analysis model to understand the resilience of SGX Group's strategies. The model currently includes transition costs, transition opportunities and physical risk perils

to assess exposure to climate-related risks and opportunities. The model will be progressively enhanced to meet

IFRS SDS requirements. We will continue to review and quantify the

Glossary

financial impact of climate-related risks and opportunities based on our model findings, in collaboration with external subject matter experts where appropriate.

SGX Group has selected scenarios provided by the Network for Greening the Financial System (NGFS) - a coalition of central banks or prudential supervisory authorities. This is in

line with industry best practices, as identified in the latest survey by the Global Association for Risk Professionals (GARP) on Climate Risk Management and would also enable comparability across organisations disclosing on climate scenario analysis. The NGFS scenarios were developed to explore a range of plausible outcomes as illustrated in the four quadrants below. SGX Group has identified three scenarios to prioritise in our scenario analysis.

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‌Material Factors

High

NGFS scenarios framework in Phase V

Net-Zero 2050 (1.5°C)

Current Policies

Hot house world

Low

Demand

Orderly

NDCs

Below 2°C

World

Delayed Transition

Fragmented

Too little, too late

Disorderly

Low

Transition Risks

Low

Physical Risks

High

  1. Net-Zero 2050 scenario models the achievement of global net-zero CO2 emissions by around 2050

    Material Factors

through stringent climate policies and innovation would limit global warming to 1.5°C. Goals such as the 2015 Paris Agreement are met. Though physical risks are limited, transition risks in these scenarios are high.

  1. Delayed Transition scenario assumes annual emissions do not decrease until 2030. Strong policies are needed thereafter to limit warming to below 2°C. Negative emissions (carbon capture innovations) are limited. Level of climate actions differs across countries and regions.

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  2. Current Policies scenario assumes that only currently implemented policies are preserved. There is no further climate action and emissions grow until 2080 leading to about 3°C of warming.

Under this scenario, physical risks are the most severe due to increased impacts of climate change.

Positioning of scenarios is approximate, based on an assessment of physical and transition risks out to 2100. Source: Network for Greening the Financial System

The scenarios were selected to include the boundaries of transition and physical risks as identified by NGFS. The market considers "Current Policies" and "Delayed Transition" as the two most likely scenarios given current geopolitics and the latest climate data.

NGFS has published pathways of the development of key variables under the respective scenarios. We used the latest available long-term pathways which were published in November 2024. These pathways were revised to incorporate an updated evaluation of the physical impacts of climate change, new country-level policies and the current geopolitical context. Where possible, variables were disaggregated to the country level. Key parameters such as asset classes relevant to SGX

Group were identified and leading products across each asset class were modelled using adjusted pathway variables obtained from NGFS. Variables used include: GHG emissions, carbon prices, energy prices, GDP of countries, level of steel production and investments in low-carbon technologies, etc. The various scenarios share similar socio-economic assumptions and a continuation of current economic trends and policies.

Key Findings from Climate Scenario Analysis and Risk Assessment

SGX Group's direct exposure to climate-related physical risks is minimal. These risks are likely to have indirect impacts, affecting future revenues and expenses rather than assets and liabilities. As a marketplace for capital raising and

trading, SGX Group does not hold significant real assets in its portfolio.

Glossary

On the other hand, the most immediate impacts are likely to be from transition risks given the highly regulated nature of the financial sector and wider trends of increasing climate-related regulations, increased corporate climate action and the suite of sustainability-focused products listed on SGX.

Physical risks

SGX Group notes that while our offices globally could be impacted by extreme weather, which is increasing in frequency and intensity globally, the direct financial impact to SGX Group is expected to be limited, as all facilities are leased and are evaluated

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‌Material Factors

for vulnerability to physical risks during the selection process. These sites are selected for their reduced exposure to weather hazards where possible.

SGX Group has identified flash floods and heatwaves as the primary physical climate risks in Singapore, where most operations are based.

The potential for operational disruption is assessed to be low, given the digitalisation of key processes and the ability of staff to work from multiple locations. These resilience measures were successfully tested during the COVID-19 pandemic.

The first of these conditions was experienced in April 2024, with a heatwave lasting over two weeks affecting the majority of Southeast Asia. This heatwave did not have an impact on SGX Group's operations in the region. The operational impact of heatwave on our data centres and trading platform has also been assessed to be minimal. We have been collaborating with experts to understand the impact of increased urban heat on our data centres. In the long term, SGX Group is not exposed to coastal flood risk given the location of our premises and the adaptive action taken by the Singapore government in terms of coastal defence. Due to the uncertain effects of global warming, we cannot reliably quantify its potential implications.

However, we are acutely aware of the threats posed by chronic physical risks to our operations and have proactively sought to understand them. One remediation effort includes a mass notification system that alerts if the primary office is unavailable due to flooding, allowing staff to work from an alternate site or remotely.

Transition risks

Regulations are anticipated to be a major factor in driving transition risks. For example, financial

authorities' ongoing efforts to address greenwashing claims, alongside the continuous launch of sustainability products and increasing investor interest, have led us to maintain our reputational risk assessment due to potential greenwashing concerns.

Another source of potential transition risk is carbon pricing. In Singapore, the government has announced plans to implement carbon taxes with a projected upper boundary of $80/ tCO2e by 2030. Though limited, SGX Group has indirect exposure to carbon taxes in the form of higher energy prices, through our energy-intensive data centre operations.

In our analysis across three scenarios, SGX Group faces minimal transition risk on operational costs due to its low GHG Scope 1, 2, and 3 footprints. In the long run, anticipated increases in emission costs are offset by reductions in energy consumption resulting from global advancements in energy efficiency.

"Looking ahead, SGX Group is committed to enhancing our climate scenario analysis within the framework of IFRS SDS reporting. We will continue to refine our assessment of physical climate risks, including flash floods and heatwaves."

On the opportunities front, under the "Net-Zero 2050" and "Delayed Transition" scenarios, SGX Group may benefit from growth and investor interest in green and sustainable products, driven by the implementation and tightening of climate policies. The increase in AUM of the iShares MSCI Climate Action

Asia ex Japan ETF, along with the broader range of listed MSCI Climate Action products, illustrates this trend. Since its launch in 2023, the AUM of the iShares MSCI Climate Action Asia ex Japan ETF has tripled. The continued adoption of SGX Group's sustainability-related products is expected to enhance SGX Group's financial performance by generating potential additional revenue.

Material Factors

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Conversely, in the "Current Policies" scenario, missed green opportunities are compensated by growth in other asset classes within our multi-asset exchange. Throughout these scenarios, SGX Group's business revenue remains resilient in the face of climate change.

Our Journey Forward

Glossary

Looking ahead, SGX Group is committed to enhancing our climate scenario analysis within the framework of IFRS SDS reporting. We will continue to refine our assessment of physical climate risks, including flash floods and heatwaves. Our scenario analysis models will also be updated with latest data releases from NGFS. The insights gained from this process will guide SGX Group's climate transition planning, contributing to a more sustainable financial sector and the decarbonisation of the economy.

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‌Material Factors

Climate-related Risks and Opportunities Across Our Business

Scenario Name Net-Zero 2050 (1.5°C) Current Policies Delayed Transition

Scenario description Strong and sustained

decarbonisation efforts driven by stringent climate policies, regulation and innovation.

Governments internationally actively align on science-based legislation and achieve net-zero GHG emissions by 2050. Climate-driven investment processes are mainstream.

Only currently implemented policies are preserved, leading to greater physical risks in the long run.

Governments take divergent approaches towards climate action legislation. Disjointed regulations across jurisdictions leading to different stages of integration of climate factors into investment processes and portfolios. There

is still some demand for climate-driven products, however, demand is dispersed or sporadic.

Currently implemented policies continue until 2030, with a strong policy shift towards decarbonisation after 2030 to limit effects of warming. Disjointed regulations

Material Factors

and integration of climate factors through to 2030, sharp united shift in focus after to limit warming to below 2°C. Climate driven investment experiences growth

in demand after 2030.

Glossary

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Time horizon

Potential result

Time horizon

Potential result

Time horizon

Potential result

Physical Risks

Acute & Chronic

-

No climate-related physical risks beyond what is presently experienced.



Flash floods and other acute weather events may disrupt operational

activities such as the processing of shares issuances for IPOs, settlement, etc. However, we view the risk of such disruptions

as having minimal impact to our operations.



Heightened risk of flash floods and other acute weather events may disrupt operational activities such as the processing of

shares issuances for IPOs, settlement, etc. However, we view the risk of such disruptions

as having minimal impact to our operations.

Heatwaves have potential to lead to operational disruption. Impact is assessed to be minimal.

Heatwaves have potential to lead to operational disruption. Impact is assessed to be minimal.

Transition Risks

Policy & Legal



SGX Group's listing rules will need to keep pace with leading

climate-related regulatory developments globally to ensure that our products and platform remain relevant.



Issuers and investors may potentially seek to list/invest in jurisdictions with less strict climate laws in the short-term to avoid

unfavourable laws and regulations.



In the short term, issuers and investors may potentially seek to list/invest in jurisdictions with

less onerous climate laws to avoid unfavourable laws and regulations.

In the medium term, issuers and investors may prefer listing on our platform given the consistent tone and clear listing requirements.

ST - short-term (1 to 3 years)
MT - medium-term (3 to 10 years)
LT - long-term (beyond 10 years)

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‌Material Factors

Scenario Name Net Zero 2050 (1.5°C) Current Policies Delayed Transition

Time horizon Potential result Time horizon Potential result Time horizon Potential result

Market & Economy

Demand for sustainable investing products and data will increase rapidly. SGX Group risks

losing market share if product launches are mis-timed,

or product development misreads market dynamics.

Reputation

SGX Group has

been strongly promoting and acting on climate action and is actively involved

in various climate action initiatives.

Nonetheless, we recognise that we may face some reputational risks due to enhanced scrutiny

of climate credentials.

Technology - SGX Group is not exposed to risk of technology obsolescence due to climate transition.

Risk of low adoption of climate-related launched products due to the market failing to integrate climate factors into portfolios. Current product suite aimed



at capturing low-carbon or

transition-driven demand may not realise expected potential.



Climate action is a core part of SGX Group's sustainability

strategy. However, we recognise that we may face some reputational risks due to enhanced scrutiny of climate credentials.

- SGX Group is

not exposed to risk of technology obsolescence due to climate transition.

In the short term, there is a risk of low adoption of climate-related launched products due to the market failing to integrate climate factors into portfolios.



Material Factors

In the medium term as policies shift, demand for sustainable

investing products and data will gain momentum.



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Climate action is a core part of SGX Group's sustainability

strategy. However, we recognise that we may face some reputational risks due to enhanced scrutiny of climate credentials.

Glossary

- SGX Group is

not exposed to risk of technology obsolescence due to climate transition.

ST - short-term (1 to 3 years)
MT - medium-term (3 to 10 years)
LT - long-term (beyond 10 years)

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‌Material Factors

SGX Group's Decarbonisation and Emissions Reduction

In FY2025, our Scope 1 emissions are largely unchanged from FY2024

as the majority of these are fugitive emissions. Our Scope 2 emissions decreased this year, following a temporary increase last year due to the reconfiguration and consolidation of our office footprint and data centres in Singapore. To remain in line with our decarbonisation pathway, we have reduced our Scope 2 emissions primarily through data centre optimisation, complemented by the procurement of RECs for our Singapore-based operations.

We continue to disclose all relevant categories for our Scope 3 emissions. This encompasses Category 1 (Purchased goods and services), Category 2 (Capital goods), Category 5 (Waste generated in operations), Category 6 (Business travel), Category 7 (Employee commuting), Category 13 (Downstream leased assets) and Category 15 (Investments). We will continue to review and disclose Scope 3 categories where relevant and work to improve the accuracy of disclosed Scope 3 categories as data availability and methodologies develop. Our

Carbon Disclosure (total, tCO2e)

10,660

15,434

7,062

14,437

11,775

3,635

3,947

3,568

24

32

30

FY2025

FY2024

FY2023

Scope 1

Scope 2 (location-based)

Scope 3

Total (absolute emissions)



Scope 3, Category 2 emissions decreased this year, following a one-off increase last year due to

renovation works associated with the reconfiguration and consolidation of our office footprint. Gases included in the calculation include CO2, CH4 and N2O and are reported in CO2e. We have expanded the scope of coverage for Scope 3, Category 15 emissions to include our JVs and Associates' emissions covering all Scope 3 categories across our value chain.

Please refer to our Performance Metrics report for details related to our emissions.

Our emissions are calculated in alignment with GHG Protocol Corporate Accounting and Reporting Standard (revised edition). SGX Group adopts an "Operational Control" boundary for our GHG and environmental reporting, as this framework allows us to effectively manage emissions from operations under our control. This approach enables us to systematically review activities and implement measures aimed at decarbonisation. An organisation has operational control if it has, or its subsidiaries have, the full authority to introduce and

18,416



implement its operating policies. This approach accounts for 100% of emissions from facilities, operations, and vehicles (whether leased or owned) over which SGX Group has operational control. To calculate the resultant GHG, we require emission factors from sources like the Singapore EMA Energy Statistics and IEA Internal Energy Factors. The GHG emissions in our FY2025 Sustainability Report have been externally verified in accordance with SSAE 3410 and SSAE 3000. Please refer to pages 52 to 58 of this report. Our targets are derived using the absolute contraction approach based on the guidance provided by SBTi and were validated by SBTi in August 2022. We remain on track to achieve these targets.

Material Factors

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While the primary focus of our decarbonisation strategy is to reduce emissions, we also acknowledge the importance of taking responsibility for the emissions generated by our daily activities. Over the years, we have proactively implemented strategies to reduce energy consumption, including

(1) replacing lighting in our SGX office

buildings with energy-efficient LEDs,

(2) minimising the operation of facilities such as elevators and lighting during off-peak hours and (3) increasing air

Glossary

conditioning temperatures in the offices. For our long-term strategy, we aim to enhance the use of renewable energy sources to promote a more sustainable future. We partner with our subsidiary, Energy Market Company (EMC), to source renewable energy.

We recognise that decarbonising our operations is a multi-year endeavour that demands commitment across the entire group. In FY2025, we will continue to make progress in our decarbonisation initiatives through cross-team collaboration, ensuring that we stay on course to achieve our net-zero targets. In addition, SGX Group board is being updated on an annual basis on our climate strategy and target progress

to ensure we stay on track and resilient long-term.

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‌Material Factors

Targets and Commitments

Short (next 12 months) and Interim (between now and 2030):

  • Continue to disclose Scope 1, 2, and 3 emissions

  • Remain on track to reduce Scope 2 absolute carbon emissions by 42% by FY2031 from FY2021 baseline

  • Our Scope 3 emissions target on engaging our data centre supplier to set science-based targets has already been achieved as of FY2022

  • We aim to optimise the energy efficiency and emissions profile of our data centres

  • A comprehensive review of our emissions reduction targets is planned to align with the prevailing leading GHG target setting framework, such as the SBTi Corporate Net-Zero Standard 2.0 expected to be issued at the end of 2025 or later or the ISO Net-Zero Standard which is also in the process of being created

  • Submit revised targets to SBTi for validation, if applicable

  • Continue to make available climate-related training for staff

    Long term (by 2050):

  • To reach net-zero emissions by 2050

Our Performance in FY2025

  • Disclosed absolute emissions and emission intensity for Scope 1, 2 and 3 in line with GHG Protocol Standards

  • Reduced Scope 2 emissions in line with our decarbonisation pathway primarily through data centre optimisation, complemented by the procurement of RECs for our Singapore-based operations

  • Completed review and disclosed all relevant Scope 3 emission categories

  • The review of our emissions reduction targets against expected revised SBTi Corporate Net-Zero Standard 2.0 could not commence as the revised standard was not yet finalised at the end of FY2025

  • Over 2,197 hours and 280 cumulative attendance of climate-related training for staff recorded

Material Factors

Glossary

Independent Limited Assurance Report

FY2025 Carbon Management - SGX Decarbonisation

Carbon Disclosure (total, tCO2e)

FY2025

FY2024

FY2023

Scope 1

24

32

30

Scope 2

3,635

3,947

3,568

Scope 3

11,775

14,437

7,062

Total (absolute emissions)

15,434

18,416

10,660

Emission intensity by revenue (per S$m)

11.9

15.0

8.9

Progressing Through Volatility

‌Material Factors SGX Group's Climate Transition Plan

SGX Group's climate transition plan demonstrates our commitments, efforts and actions to support the transition to a low-carbon and resilient future. Building upon the analysis of climate-related risks and opportunities using the TCFD and IFRS SDS framework, our strategy and actions include decarbonisation of our operations and aim to support the net zero transition of our marketplace and ecosystem using different levers. Please refer to our full Sustainability Report FY2024 for details of our climate transition plan.

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With reference to









Foundation

Objectives and priorities

  • To reach net-zero by 2050

  • Support the net-zero transition of our operations, marketplace and ecosystem through three key strategic priorities

    Implementation Strategy

    Strategic priority 1:

    SGX Group's own decarbonisation and emissions reduction

  • Implementing our science-based targets and reporting progress in our sustainability report since FY2021

    Strategic priority 2: Facilitate credible transition of our marketplace and support capital mobilisation through sustainable/ transition products and solutions as a trusted infrastructure provider

    Engagement Strategy

    Strategic priority 3:

    Market stewardship and influence through ecosystem collaboration

    Internal

  • Regular and accessible climate and sustainability-related education and training for staff to implement SGX Group's climate priorities and policies

    External

  • SGX Group's capacity development initiatives involve active engagement with a broad range of ecosystem stakeholders to promote climate-related disclosures and advance climate actions

    Governance

    Material Factors

Independent Limited Assurance Report

Robust governance structures across various levels are in place and foundational at SGX Group for driving our climate and sustainability ambitions and actions

Glossary

Metrics and Targets

Focus areas:

Exchange-focused targets

  • Emissions reduction and net-zero targets

  • Maintain robust governance structure and adequate staff training to support our climate actions

    Market-focused targets

  • Transparency and education: Provide training, awareness activities and guidance to encourage market participants to advance their climate-related disclosures and promote net-zero commitments

  • Products and services: Promote adoption of climate focused products, solutions and platforms. Collaborate with ecosystem partners to develop products and solutions that incorporate climate and sustainability considerations

  • Policy, persuasion and engagement: Proactive engagement with stakeholders, including market participants, partners, policy makers and standard setters, to advance net-zero commitments

    Progressing Through Volatility

    ‌Material Factors SGX Group's Climate Transition Plan Progress

    Material Factors

The following section summarises the progress of SGX Group's Climate Transition Plan, which was implemented in FY2024. This plan brings together our climate and sustainability efforts over the years into one coherent, long-term strategy and action plan, reinforcing our commitments to walk and lead the transition journey with our ecosystem. A high-level overview of our Climate Transition Plan is presented on page 29 of this report. For detailed information, please refer to pages 25 to 33 oF our FY2024 Sustainability Report. We recognise that climate transition planning is an iterative process and will look to review our transition plan in FY2026 to ensure its robustness and relevance. This aligns with our plan to conduct reviews biennially from FY2024 through FY2031 and subsequently every five years or as needed.

Target Metrics and Disclosures Our Progress in FY2025

Exchange-focused

Emissions reduction Short-term (next 12 months)

and interim (between now and 2030)

  • Continue to disclose Scope 1,

    2 and 3 GHG emissions

  • Remain on track to reduce Scope 2 absolute carbon emissions by 42% by FY2031 from FY2021 baseline

  • Our Scope 3 emissions target on engaging our data centre supplier to set science-based targets has already been achieved as of FY2022

  • Conduct a comprehensive review of our emissions reduction targets, including expanding relevant Scope 3 emission categories disclosed and potential adjustment due to SBTi Corporate Net-Zero Standard 2.0

  • Submit revised targets to SBTi for validation

    Long-term (by 2050)

  • To reach net-zero emissions by 2050

  • Scope 1, Scope 2 and Scope 3 GHG emissions

  • Describe actions to remain on track for our targets

  • Disclosed absolute emissions and emission intensity for Scope 1, 2 and 3 in line with Greenhouse Gas Protocol Standards

    Independent Limited Assurance Report

  • Reduced Scope 2 emissions in line with our decarbonisation pathway primarily through data centre optimisation, complemented by the procurement of RECs for our Singapore-based operations

  • Completed review and disclosed all relevant Scope 3 emission categories

    Glossary

  • A comprehensive review of our emissions reduction targets is planned to align with the prevailing leading GHG target setting framework, such as the SBTi Corporate Net-Zero Standard 2.0 expected to be issued at the end of 2025 or later or the ISO Net-Zero Standard which is also in the process of being created

  • Please refer to our material factor "Climate Management" on pages 21 to 28 of this report for more details