10 April 2026

Mr. Yuen Kuan Moon
Group Chief Executive Officer, Non-independent and Executive Director
Singapore Telecommunications Limited (Singtel)

Re: ESG Concerns Regarding Gulf Development Public Company Limited Investments

Dear Mr. Yuen Kuan Moon,

We represent a coalition of civil society movements, community networks, and environmental advocacy organizations from Thailand. We are writing to you in your capacity as one of the largest shareholders of Gulf Development Public Company Limited (GULF). Public disclosures indicate that Singtel holds approximately a 7.73 percent stake in the company, a position that grants your institution significant influence.

Before detailing our specific concerns, we wish to provide a summary of the potential material ESG risks we have identified within GULF’s portfolio which we believe require your urgent attention :

1. 1. Governance & Human Rights: The use of Strategic Lawsuits Against Public Participation (SLAPPs) against critics, which contradicts both international standards, Singtel’s policies and, GULF’s own internal Human Rights Policy.
   2. Project-Level Environmental Risks: Significant concerns regarding inadequate public participation, land-use restrictions, and water stress in an already resource-constrained region associated with Burapa Power Project in Chachoengsao.
   3. Transboundary Ecological Threats: High-impact hydropower projects on the Mekong River(Pak Beng, Pak Lay, and Luang Prabang) that threaten regional food security, livelihood and biodiversity.
   4. Climate Alignment Risk: A fossil-gas expansion strategy that creates “financed emissions” for Singtel, potentially undermining your SBTi-validated Net Zero 2045 roadmap.

As Singtel has publicly committed to the United Nations Guiding Principles on Business and Human Rights and maintains an ambitious climate roadmap, we believe you have a vital interest in ensuring that your investee companies do not undermine these very standards. We also note Singtel Group’s Environmental Policy, which commits the company to “understanding, managing and minimizing the environmental impact of our business investments, operations, products and value chain, ” including through the identification and management of material environmental impacts and engagement with investee companies to improve environmental performance.

Strategic Lawsuits Against Public Participation (SLAPPs) and Governance Risks

GULF’s track record on the use of litigations against critics raises serious ethical concerns, particularly regarding its potential violations of fundamental human rights regarding the right to freedom of expression outlined in Article 19 of the Universal Declaration of Human Rights and the International Covenant on Civil and Political Rights, of which Thailand is a party.

Based on publicly available information, since 2020 the company has initiated a number of civil and criminal defamation cases against individuals, with total damages claimed exceeding 900 million baht (approximately USD 28.12 million). In many instances, the defendants appear to have expressed opinions, raised concerns, or questioned aspects of the company’s operations in the context of broader public policy debates. These include issues related to Thailand’s energy governance, electricity pricing structures, transparency of power purchase agreements, and rising electricity costs. Further details are outlined in Appendix 1.

There are recurring features across these cases which include the pursuit of substantial damages that may be perceived as disproportionate, as well as legal actions that reportedly extend beyond primary speakers to include individuals involved in the secondary dissemination of information. Such patterns may contribute to a chilling effect on public participation and open debate on matters of public interest.

In some cases, parliamentarians and political actors engaged in parliamentary debate have also faced legal action. Such actions may raise concerns regarding the principle of parliamentary privilege, which is intended to protect legislators in the performance of their duties, and could have implications for the effective functioning of democratic checks and balances.

These worrying corporate practices were viewed by many human rights watchdogs as an example of strategic lawsuits against public participation, or SLAPPs, a form of litigation used to silence or discourage criticism and public debate. They are also in direct contradiction to GUFL’s own Human Right Policy which commits to respect internationally recognized human rights standards, including the protection of freedom of expression, stakeholder engagement, and alignment with the United Nations Guiding Principles on Business and Human Rights. These standards require companies to avoid infringing on the rights of individuals and to ensure that affected stakeholders can participate meaningfully in decisions that impact them. The use of SLAPPs presents serious governance risks that underminds open public debate on energy policy and corporate conduct which could expose investors to reputational harm through association with perceived suppression of civic participation.

Singtel’s Group Human Rights Policy explicitly commits to the UN Guiding Principles on Business and Human Rights (UNGPs), which mandate that companies must not only respect human rights in their own operations but also use their leverage to prevent or mitigate adverse impacts linked to their business relationships.

For a company with Singtel’s global ESG leadership profile, association with litigation widely perceived as SLAPPs could raise serious questions regarding alignment with responsible governance and human rights commitments. As a significant shareholder in GULF, Singtel is in a position to exercise its influence to encourage responsible corporate conduct and alignment with internationally recognized human rights standards.

Environmental and Social Risks Associated with the Burapa Power Project

Burapa Power Project is a 540 MW fossil gas-fired combined-cycle power plant currently under construction in Phanom Sarakham District, Chachoengsao Province, Thailand. Originally proposed as a coal-fired power plant, the project faced strong community opposition since 2008 and was ultimately restructured as a gas-fired power plant in 2019, with GULF becoming a shareholder in early 2020.

The construction of high-voltage transmission lines needed to connect Burapa Power Project to a nearby substation caused serious concern among affected communities as it may result in severe restriction on the land owners’ rights to use their land and put local livelihoods, food security, and economic stability at risk.

The transmission corridor spans 14.18 kilometers with the width of 60 meters and landowners whose properties lie within this Right of Way (ROW) are subject to safety regulations that restrict land use. These regulations prohibit activities such as bringing cranes, forklifts, loaders, or excavators into restricted areas, as well as constructing houses, buildings, or residential structures. The planting oF perennial crops or trees is also banned. As a result, affected families will lose access to a total of 531.75 rai (around 85 hectares) of agricultural land, on which most livelihoods directly depend.

A group of affected landowners has filed administrative lawsuits that have been accepted by Thailand’s Administrative Court. The plaintiffs argue that the project failed to comply with the Public Participation Guidelines in the Environmental Impact Assessment (EIA) process established by the Office of Natural Resources and Environmental Policy and Planning. These guidelines set out legally required procedures to ensure public hearings and meaningful participation by communities affected by the project.

They argue that the project is proceeding without their consent as the consultation process excluded many residents who are directly impacted by the project and failed to ensure full disclosure of critical information for informed decision-making. In particular, some affected landowners reported that they did not receive timely prior notification, leaving them unable to properly assess the consequences for their rights and livelihoods. This oversight contravenes the Public Participation Guidelines in the

Environmental Impact Assessment (EIA) process under the Office of Natural Resources and Environmental Policy and Planning (ONEP).

In terms of water stress and resource conflict, Burapa Power Project could severely strain Chachoengsao’s already scarce water resources, intensifying competition between industrial users and local communities who depend on the same water sources. The project’s planned extraction of 12,000 cubic meters of water per day will exacerbate existing water stress and heighten the risk of resource conflicts.

According to the EIA report, Burapa Power Project will use water during its operation phase at a rate of 12,000 cubic meters per day. The water will be supplied by Industrial Water Supply Co., Ltd. and stored in one reservoir with a capacity of approximately 46,055 cubic meters. Most of the water, around 11,753 cubic meters per day, will be used in the cooling process. Industrial Water Supply Co., Ltd. has been granted permission by the Royal Irrigation Department to pump water from Khlong Rabom only during the months of July to October (a total of four months).

However, Chachoengsao province already faces chronic water shortages. As of September 2023, the province’s five major and medium-sized reservoirs held merely 19.46% (94.12 million m³) of their total capacity. Meanwhile, total annual water demand across sectors was :

• Domestic use: 41.89 million m³
• Ecosystem maintenance: 18.25 million m³
• Agriculture: 1,304.73 million m³
• Industry: 108.92 million m³

Khlong Rabom and the connected Khlong Thalat system already serve multiple major industrial users and regional water authorities which already exceed 150 million cubic meters annually. For example, T-Water (EEC) Co., Ltd. alone has rights to extract up to 80 million cubic meters per year, and combined provincial waterworks consume more than 60 million cubic meters per year.

Burapa Power Project’s additional demand of 12,000 m³ per day, significant given existing water stress, will intensify competition for limited resources. This heightens the risk of severe water scarcity and raises legitimate concerns among local communities and stakeholders about potential resource conflicts, threatening both human livelihoods and ecosystem sustainability.

Transboundary Ecological and Human Rights Risks in the Mekong Basin

Beyond Thailand’s borders, GULF’s heavy investment in hydropower projects along the Mekong River mainstream—including the Pak Beng, Pak Lay, and Luang Prabang dams—exposes shareholders to immense transboundary liabilities. These projects have been met with sustained criticism from regional experts and the National Human Rights Commission of Thailand. Data by International Rivers highlights that the cumulative impacts of these projects, together with other dams already operating or planned along the Mekong, threaten fisheries, sediment flows, and river ecosystems that support the livelihoods of millions of people across the basin. Despite repeated warnings from communities, civil society networks, and oversight bodies, including Thailand’s National Human Rights Commission of Thailand, these projects have continued to advance. This raises serious concerns regarding environmental degradation, transboundary harm, and the absence of comprehensive human rights and climate impact assessments—issues that may also conflict with Singtel’s stated commitment to incorporate environmental considerations into its business decisions and to protect biodiversity where relevant.

Pak Beng Hydropower Project

The Pak Beng Hydropower Project, a 912-MW dam located on the Mekong River. The project could displace approximately 6,700 people from 25 villages, while communities and civil society organizations across the Mekong basin have for nearly a decade warned that it threatens food security, damages riverbank gardens, and restricts access to land, water resources, and fisheries that are central to local livelihoods. Reviews by International Rivers have found significant shortcomings in the project’s Transboundary Environmental Impact Assessment (TbEIA) and Cumulative Impact Assessment (CIA), including inadequate modeling of fish migration, sediment flows, and flood risks for downstream communities. These deficiencies—such as incomplete fisheries studies, hydrological models lacking critical seasonal data, and the failure to assess cumulative impacts from multiple Mekong mainstream dams—could lead to increased flood risk, declining agricultural productivity, and the erosion of traditional river-based livelihoods. Communities and civil society networks have continued to raise concerns through petitions, advocacy, and human rights complaints grounded in the UN Guiding Principles on Business and Human Rights. Between 2024 and 2025, Fair Finance Thailand issued open letters urging financial institutions to withhold financing until key safeguards are met, highlighting incomplete transboundary impact assessments, and potential non-compliance with the Equator Principles. In March 2025, Thailand’s National Human Rights Commission of Thailand and the Parliamentary Committee on Land, Natural Resources and Environment initiated investigations into complaints related to the project, including alleged human rights violations, lack of disclosure of project information, and concerns over the broader transboundary impacts of hydropower development along the Mekong River.

In May 2025, the Ombudsman issued a report on the complaint concerning the Pak Beng Dam, recommending that the Thai Cabinet postpone the Power Purchase Agreement (PPA) due to concerns over transboundary impacts, including risks to border stability linked to changes in river flow, as well as socio-economic impacts on communities along the Thailand–Laos Mekong border.

Pak Lay Hydropower Project

The Pak Lay Hydropower Project, another Mekong mainstream dam, has raised similar environmental and human rights concerns. As the fourth of eleven dams proposed for the lower Mekong River, the project would compound the cumulative impacts of earlier controversial dams such as Xayaburi Dam,

Don Sahong Dam, and Pak Beng Hydropower Project. Studies by the Mekong River Commission warn that the expansion of mainstream dams could severely damage the region’s ecological health and economic vitality, potentially causing a 30–40% decline in Mekong fisheries by 2040 and drastically reducing sediment flows vital to the Mekong Delta. The project is expected to directly and indirectly affect more than 22,000 people, with some villages facing relocation, while communities in neighboring Thailand may also experience cross-border impacts. Concerns about the quality and credibility of the project’s Transboundary Environmental and Social Impact Assessment have also been raised as 90% of the content appears to be copied and pasted from that of the Pak Beng project without adequately assessing site-specific impacts.

Luang Prabang Hydropower Project

The 1,460-MW dam on the Mekong River is located 25 kilometers upstream from the historic city of Luang Prabang—a UNESCO World Heritage Site and just 4 kilometers from the sacred Pak Ou Caves, home to centuries-old Buddhist shrines. Experts and civil society groups warn that the dam could significantly alter the Mekong’s natural flow, disrupt fisheries and river-based livelihoods, and damage wetlands and riverbanks that are integral to the city’s cultural and ecological heritage. The project is expected to displace more than 500 families across around 20 villages and could further exacerbate the cumulative impacts of other mainstream dams such as the Xayaburi Dam.

Serious safety concerns have also been raised because the dam site lies within an active earthquake zone along the Loei–Dien Bien Phu Fault, yet no clear emergency response plan has been publicly disclosed to address potential risks from earthquakes, including structural damage or dam failure. A monitoring report by UNESCO in April 2022 recommended that project proponents and the Lao government adopt a precautionary approach and consider relocating the project due to its potential impacts on the World Heritage Site.

Misalignment with Singtel’s Net Zero and Science-Based Targets

Singtel has demonstrated commendable leadership by committing to a Net Zero 2045 timeline and securing validation from the Science Based Targets initiative (SBTi) for its 1.5°C-aligned pathway.

However, the ongoing expansion of gas-fired power infrastructure by GULF, exemplified by the Burapa Power Project, presents a direct challenge to these commitments. In a global energy landscape where the International Energy Agency (IEA) has clearly stated that no new fossil fuel infrastructure is compatible with a 1.5°C scenario, GULF’s strategy contributes significantly to “financed emissions” that fall under Singtel’s Scope 3 responsibility. Maintaining a significant stake in fossil fuel expansion, particularly in a Thai energy market already facing substantial power oversupply, raises questions about the alignment between your investment portfolio and your climate pledges.

We note that Singtel’s Environmental Policy commits the company to engaging with stakeholders in its value chain to review and improve environmental performance. As one of the largest shareholders of GULF, Singtel is therefore in a position to exercise meaningful leverage to address the risks outlined in this letter.

In light of these concerns, we respectfully urge Singtel to:

• Initiate a high-level engagement with GULF leadership to mandate a comprehensive review of the Burapa Power Project’s ESG risk assessment and its current mitigation strategies. Given the region’s water stress and the national energy oversupply, Singtel should advocate for a more rigorous approach to minimizing the project’s impact and evaluating its long-term viability as a potentially stranded asset.
• Engage directly with GULF’s leadership to seek clarification on why the company’s litigation strategy appears to contradict its own Human Rights Policy. Singtel should advocate for the cessation of SLAPP suits and the adoption of a genuine grievance and engagement mechanism that protects freedom of speech.
• Engage with GULF to conduct a thorough review of its human rights and environmental policies and due diligence processes, ensuring alignment with both national and international standards.

We would welcome the opportunity to engage in a formal dialogue with your leadership team to provide further evidence from affected communities. We look forward to your response regarding the steps Singtel will take to address these material risks.

Yours sincerely,