Writing the playbook for #COVID19

Some of my co-workers recently asked for more concrete signposts on what SGX RegCo would be doing in this new world even as Phase 2 of the rollback of the so-called Singapore circuit-breaker measures are almost upon us. As I said at a recent staff town hall, we have no playbook. In fact, this is our opportunity to write the playbook and here are five things that I think we need to do.

1)     Adjust to the new reality. We’ve seen this most clearly in the retail and restaurant businesses. Customers aren’t coming to us anymore, so we have to go to them. Hence the pivot to online and delivery services. Similarly for us, social distancing is going to be with us for a while. That’s why Listing Compliance (LC) and Listing Policy and Produce Admission (LPPA) have been working so hard on granting extensions of time for holding AGMs and rolling out the new virtual AGM rules. Similarly, Member Supervision (MS) has had to pivot from doing onsite inspections to offsite monitoring without compromising the degree of assurance. And IPO Admissions (IPOA) has implemented virtual lodgment of Catalist offers with Southern Alliance Mining Ltd being the first to do so.

2)     Reward our supporters. Or at the very least, don’t let them down. You want to take care of your core customers who stick by you. So for example, chains like Dunkin Donuts, Target and Walmart have doubled the reward points for members of their loyalty programs who continue to order online, or use delivery and pickup. Similarly, LC and LPPA have allowed companies that have postponed their AGMs to declare interim dividends to their shareholders, and reminded companies which have taken advantage of our extensions of time to report their results to strictly comply with our enhanced continuous disclosure rules. In the same way, MS has worked closely with our members to help them cope with increased trading volumes during this period, even as more and more of their staff have to WFH.

3)     Connect emotionally, not just physically. Some of us are feeling particularly vulnerable right now. Whole Foods responded by reserving certain shopping hours for senior citizens. LC and LPPA responded by revising our guidance for holding AGMS and announcing the revisions at least three or four times as the situation kept changing for our listed companies. We have also suspended entry into our financial watch list until 2021, and we removed the MTP (Minimum Trading Price) watch list effective 1 June. Surveillance has been sensibly restrained in issuing trading queries to companies because of big movements in their share price, assisted by the recently introduced AI that factors macro trends into our SMARTs alerts system. At the same time, feedback from market participants has increased, and the Whistle-Blowing Office (WBO) is working closely with LC and IPOA to ensure they are being heard.

4)     Turn crisis into opportunities In response to the changes in demand, many airlines are now retrofitting their passenger planes into cargo planes. Similarly, in view of the social distancing measures, Regulatory Development and Policy (RDP) and MS have been working with Risk to change the way we manage member defaults to a less resource-intensive process that no longer requires any physical interaction with retail customers. LC and LPPA are also exploring how we can encourage market participants to adopt fully electronic notification and payment systems for meetings and corporate actions.

5)     Acknowledge there are sudden financial constraints. Facebook has responded to the inordinate impact on small offices and homes offices (SOHO) by setting up a $100m SOHO fund. Similarly, we have set up an SGX Care Package, and LC has increased the share issue mandate for mainboard companies from 50% to 100% of share capital so that companies can raise more funds more easily.

Meanwhile, we continue to look into ways and means to help our customers and stakeholders manage the challenges that COVID-19 has presented. With Phase 2 coming up, what the new reality is will also change and we will continue to look into things we need to amend or improve upon.