SGX Listing Manual: Materiality Matrix
Operationalizing disclosure triggers. When an event is “material” under the manual, it triggers an immediate legal obligation for corporate action.
Qualitative Disclosure Test
Information is material if it is “Price-Sensitive” (affects value) OR “Trade-Sensitive” (influences investor decisions regardless of immediate price impact).
Knowledge
“Issuer becomes aware of info concerning itself or subsidiaries…”
Is it Material?
Mandated Action
Select an assessment to determine your legal obligation under Rule 703.
Quantitative Benchmarks (Chapters 9 & 10)
Acquisitions & Realisations
Materiality defined by the highest “Relative Figure” among Assets, Profits, Market Cap, or Equity.
Action: Immediate SGXNet announcement.
Action: Announcement + Circular + EGM Approval.
Interested Person Transactions (IPT)
Materiality linked to Group Net Tangible Assets (NTA).
Action: Immediate announcement + Audit Committee view.
Action: Announcement + IFA Opinion + Shareholder Approval.
Operational Materiality Radar
SGX explicitly flags these events. Each card represents a mandatory disclosure trigger when the impact is deemed “material.”
Chapter 12, Listing & Reporting: Governance Ledger
◈ Internal Controls
If material weaknesses are identified, they MUST be disclosed in the Annual Report with remediation plans.
◈ Material Contracts
Disclosure in Annual Report for all material contracts involving Directors/CEOs/Shareholders.
◈ Material Properties
Annual Report must disclose details of land/buildings considered material by the directors’ judgement.
◈ IPO & Prospectus (Rule 246)
Pre-listing, applicants must inform SGX of material changes and disclose material weaknesses in systems.