Complaint says Korea’s largest electric utility misled investors, risking violation of Singapore securities law 

May 19, 2025 (SEOUL) – A whistleblower complaint filed today by Solutions for Our Climate (SFOC), a climate advocacy organization, with the Singapore Exchange’s (SGX) Whistleblowing Office accuses Korea Electric Power Corporation (KEPCO), South Korea’s largest electricity utility, of failing to disclose material climate-related risks in its $11 billion Global Medium Term Note (GMTN) Program listed on SGX. 

Finalized in February 2025, the bond attracted major global investors including BlackRock, Vanguard, MetLife Inc., TIAA-CREF, and Janus Henderson, with lead underwriting support from Citibank, HSBC, JPMorgan, and Bank of America. These stakeholders may have overlooked their responsibility to ensure adequate climate and financial risk assessment.  

Key Allegations: Climate Risk Omissions in Bond Filings 

According to the filing, KEPCO failed to disclose: 

• Continued reliance on coal-fired power until 2050, misaligned with global decarbonization goals and the Paris Agreement; 

• Financial exposure to liquefied natural gas (LNG) price volatility, amid declining global demand and delays or cancellations in key LNG infrastructure projects; 

• Misrepresentation of hydrogen-LNG and ammonia-coal blends as "carbon-free" in regulatory and investor communications, contrary to emerging international standards. 

These omissions obscure the broader climate implications of KEPCO’s energy strategy. Continued coal use until 2050 runs counter to the Paris Agreement’s 1.5°C target, which requires advanced economies to phase out coal by 2030 according to the IEA. LNG exposure adds further uncertainty, as global LNG demand declines due to renewables growth, infrastructure delays, and policies targeting methane emissions. 

Labeling hydrogen and ammonia fuel blends as “carbon-free” misleads stakeholders, given their fossil-based inputs and substantial lifecycle emissions. Experts warn such framing can contribute to greenwashing and conceal the true risk profile of fossil-based transition technologies. 

These alleged failures may breach Rules 603, 313 of the SGX Mainboard Rules, covering the obligation to disclose sufficient and customary information in the offering memorandum to ensure that targeted investors can make informed decisions based on a full understanding of the issuer’s business, financial condition, prospects, and risks. 

KEPCO’s Financial Exposure and Strategic Shift 

Facing operational losses, KEPCO has increasingly relied on debt to maintain liquidity. Its recent shift away from green and sustainability-linked bonds towards conventional financing has raised concerns among ESG-conscious investors, further casting doubt on the utility's energy transition strategy. 

“Investors deserve full transparency about climate-related risks, not selective disclosures or misleading green claims. KEPCO’s failure to disclose its long-term coal reliance, overseas coal expansion, and volatile LNG exposure while promoting hydrogen and ammonia co-firing as ‘carbon-free’ raises serious red flags,” said Gwanhaeng Lee, Senior Foreign Counsel at SFOC. “These omissions aren’t just technical oversights. They undermine investor trust and regulatory integrity. Climate risks are financial risks and concealing them in a securities filing risks misleading the market.” 

Regulatory Scrutiny Urged 

The whistleblower is urging SGX RegCo to investigate whether KEPCO violated its disclosure obligations. SGX requires issuers to fully disclose material risks, especially those with financial or reputational impact. 

“This goes beyond one company’s climate blind spots — it’s about protecting the integrity of the financial system,” said Ayleen Lippert, Climate Finance Researcher at SFOC. “When issuers like KEPCO misrepresent fossil fuel-related risks, they distort the market and erode investor trust. Backing such opaque bond enables poor financial stewardship and obstructs the shift to a more resilient, sustainable economy.” 

A Test Case for Climate Accountability 

The case could serve as a test of SGX’s regulatory posture on climate disclosure, at a time when international markets are stepping up enforcement against greenwashing, stranded asset risks, and fossil fuel dependencies. 

ENDS.  

Solutions for Our Climate (SFOC) is an independent nonprofit organization that works to accelerate global greenhouse gas emissions reduction and energy transition. SFOC leverages research, litigation, community organizing, and strategic communications to deliver practical climate solutions and build movements for change.     

For media inquiries, please reach out to Yi Hyun Kim, Communications Officer, yihyun.kim@forourclimate.org.