StarHub Sustainability Report 2025: Examining Climate Transition, ESG Governance and Digital Infrastructure Resilience

StarHub Ltd, a Singapore-listed telecommunications and digital services group, has published its Sustainability Report 2025, providing insight into how sustainability considerations intersect with its network infrastructure, workforce, customer relationships and broader value chain. Operating in an increasingly data-intensive economy, StarHub faces environmental pressures associated with electricity consumption and technology infrastructure, alongside growing expectations concerning cybersecurity, service reliability and digital inclusion. These characteristics make its sustainability performance relevant beyond conventional emissions indicators.

The report presents sustainability as part of StarHub's operational resilience and business strategy. Its disclosures suggest an effort to connect environmental management, human capital and digital trust with long-term value creation, although progress varies across these dimensions.

Reporting Background and Regulatory Context

Covering 1 January to 31 December 2025, the publication represents StarHub's fifteenth annual sustainability disclosure and its first standalone Sustainability Report. It has been prepared in accordance with the GRI Standards 2021, references Singapore Exchange sustainability reporting requirements and incorporates telecommunications-specific SASB disclosures. StarHub also conducted an ISSB gap analysis to identify improvements needed for alignment with international sustainability disclosure standards.

Singapore's sustainability reporting framework is undergoing a phased transition towards ISSB-based climate disclosures. Under the revised ACRA and SGX RegCo roadmap, all listed companies report Scope 1 and 2 greenhouse gas emissions from FY2025, while broader climate disclosure requirements depend on listing category and market capitalisation. External limited assurance over Scope 1 and 2 emissions becomes mandatory for listed companies from FY2029.

Against this background, StarHub's reporting provides evidence of preparation for increasingly structured sustainability disclosure. However, incorporating elements of IFRS S2 and undertaking gap analysis should not be confused with establishing full compliance with the ISSB Standards.

Governance Architecture and Accountability

StarHub's sustainability governance framework places ultimate oversight with its Board of Directors, supported by the Risk and Sustainability Committee and management-level risk governance arrangements. The committee held four meetings during 2025, addressing sustainability priorities including emissions performance, supplier engagement and climate-related risks. Cross-functional sustainability advocates support implementation across operational divisions.

A significant governance feature is the incorporation of two climate-related indicators into long-term performance incentives for C-suite executives and key management personnel. These relate to Scope 1 and 2 emissions reduction and renewable electricity consumption, with StarHub reporting achievement of its 2025 sustainability-linked indicators.

This linkage may strengthen accountability by connecting environmental performance with executive remuneration. Nevertheless, its effectiveness over time will depend on sustained emissions reductions, the ambition of future targets and the extent to which sustainability considerations influence investment and procurement decisions.

Materiality Approach and Risk Prioritisation

StarHub conducted a double materiality assessment in 2025, considering both the financial implications of sustainability risks and opportunities and the company's impacts on people, society and the environment. The assessment involved research, peer benchmarking, stakeholder engagement and management validation. Its outcome informed a simplified sustainability framework comprising Sustainable Operations, People and Partnerships, and Responsible Value Creation.

The company distinguishes between foundational issues, such as climate transition, workforce resilience and ethical conduct, and strategic topics including cybersecurity, customer experience, innovation and network reliability. This distinction is particularly relevant for telecommunications businesses, where operational continuity and digital trust can be material to financial performance.

Double materiality also offers a broader perspective than the investor-focused financial materiality underpinning ISSB disclosures. StarHub's approach may therefore provide a basis for addressing different stakeholder expectations, although the assessment itself does not establish compliance with other reporting regimes such as the European Sustainability Reporting Standards.

Climate, Supply Chain and Social Dimensions

StarHub has committed to achieving net-zero greenhouse gas emissions across its value chain by 2050, supported by Science Based Targets initiative-validated objectives. Its 2025 combined Scope 1 and market-based Scope 2 emissions reached 50,474 tCO2e, representing a 22.2% reduction from the 2021 baseline. Renewable electricity accounted for 28.7% of total electricity consumption, compared with 17.2% in 2024.

The company targets a 50% reduction in Scope 1 and 2 emissions by 2030, alongside a 25% reduction in selected Scope 3 categories. However, emissions within those targeted Scope 3 categories were 19.1% above their 2021 baseline in 2025, leaving the company off track against its near-term ambition. Its total reported Scope 3 footprint was 275,028 tCO2e, with purchased goods and services accounting for more than 60%.

This imbalance illustrates a recurring challenge for telecommunications operators: operational decarbonisation can progress faster than reductions embedded in equipment procurement, purchased services and customer-related activities. StarHub has responded by revising its Supplier Code of Conduct, strengthening supplier engagement and developing an updated value-chain decarbonisation roadmap. All newly onboarded suppliers completed self-assessment questionnaires in 2025, but questionnaire completion does not itself demonstrate verified supplier performance or emissions reductions.

Beyond carbon, StarHub reported 85.3 tonnes of waste, including 77.1 tonnes of recycled electronic waste, and approximately 8.8 megalitres of water use within its narrower reporting boundary. Circularity initiatives include device refurbishment, take-back arrangements and technology lifecycle management. These activities provide a foundation for wider resource-efficiency management, although the report does not establish comprehensive alignment with TNFD nature-related disclosure recommendations.

Employment and Human Capital Development

StarHub reported 1,545 employees in 2025, compared with 1,638 in 2024. Male employee turnover increased from 13.8% to 18.4%, while female turnover rose from 15.7% to 19.3%. These figures warrant attention when assessing talent retention and organisational change, although the report does not provide sufficient evidence to attribute the movements to a single cause.

The company invested approximately S$1.3 million in employee training and development, reporting 96% participation and more than 16,300 learning hours. However, the average annual training hours indicator declined from 11.7 hours in 2024 to 8.88 hours in 2025, indicating that headline training investment should be assessed alongside the intensity and coverage of learning.

Women represented 36.4% of Board members and 37.5% of senior management. While these figures provide useful diversity indicators, continued evaluation of career advancement, employee retention and pay outcomes would offer a more complete understanding of workforce inclusion.

Occupational Health and Safety

StarHub reported zero work-related fatalities and zero recordable work-related injuries in 2025, compared with three recordable injuries in 2024. Its occupational health and safety management arrangements include hazard identification, preventive controls, incident investigation and employee reporting channels. A Workplace Safety and Health Committee met quarterly to oversee implementation and address operational risks.

The improvement is a positive reported outcome, but injury statistics require careful interpretation alongside working hours, workforce coverage and contractor exposure. For telecommunications companies, contractors performing infrastructure installation, maintenance and technical operations can face different occupational hazards from office-based employees. Greater visibility into contractor safety outcomes could further strengthen the assessment of workplace risk management.

Product and Service Responsibility

For telecommunications operators, service quality and cybersecurity are closely connected to corporate responsibility. StarHub reported mobile broadband availability exceeding 99.95% and 100% fibre broadband network availability in 2025. The company also introduced a blended Engagement and Satisfaction Score of 41.8, establishing a broader customer experience measurement baseline.

Cybersecurity remains a strategic material issue. StarHub reported zero substantiated complaints concerning customer privacy breaches or loss of customer data within its operations, supported by a cybersecurity governance framework referencing NIST guidance and ISO/IEC 27001. Its employees achieved a consistently reported 90% no-click rate in monthly phishing simulations, while the company set an ambition to attain Cyber Trust Mark Tier 5 certification in 2026.

These disclosures indicate structured management attention to information security. Nevertheless, the absence of substantiated complaints should not be interpreted as eliminating cybersecurity exposure, particularly as networks become increasingly dependent on cloud infrastructure, AI-enabled services and external technology partners.

Philanthropy and Community Impact

StarHub reported more than S$700,000 in donations and in-kind sponsorships during 2025, alongside approximately 900 employee volunteering hours benefiting more than 3,000 individuals. Its initiatives focused on digital inclusion, education, cybersecurity awareness and support for disadvantaged groups. Community beneficiaries included young people, persons with disabilities and migrant workers.

The approach reflects a potential connection between corporate social investment and StarHub's telecommunications capabilities. Providing connectivity, digital devices and online safety education may generate practical benefits beyond conventional financial donations. Future disclosure could become more outcome-oriented by measuring improvements in digital access, skills and participation rather than principally reporting expenditure and beneficiary numbers.

Metrics, Targets and Data Robustness

StarHub provides quantitative indicators covering emissions, energy, resource consumption, employment, diversity, safety and customer-related matters. Its SBTi-validated climate objectives establish medium- and long-term reference points, while its climate scenario analysis considers physical and transition risks across Singapore and Malaysia. Scenarios address flooding, heatwaves and carbon-price exposure, linking environmental uncertainty with potential operational costs.

Several indicators nevertheless require qualification. Scope 1 emissions increased 59.9% year on year, primarily because of refrigerant top-ups, while total energy consumption increased 1.6%. Renewable electricity accounting includes power procurement arrangements and unbundled renewable energy certificates, making the distinction between contractual renewable attributes and physical electricity system decarbonisation important.

The company reported a 6.1% year-on-year reduction in total Scope 3 emissions, but methodological changes limit direct comparability. Improving supplier-level data, maintaining consistent calculation methods and explaining significant revisions will be essential for meaningful longitudinal assessment.

Assurance, Credibility and Comparability

KPMG LLP issued an independent limited assurance report dated 1 April 2026 under Singapore Standard on Assurance Engagements 3000 (Revised). Its engagement covered selected GRI indicators, including specified energy, emissions, waste, workforce and occupational safety information. The assurance report also addressed selected SGX sustainability reporting components.

However, the assurance scope explicitly excluded the climate-related disclosure component under SGX Rule 711B, and the selected indicators did not constitute assurance of the entire sustainability report. This distinction is important when interpreting the credibility of transition plans, scenario analysis and Scope 3 disclosures.

Another comparability limitation concerns organisational boundaries. Group-wide greenhouse gas reporting uses an operational control approach, whereas several other ESG indicators cover StarHub Ltd and specified wholly owned subsidiaries rather than all group entities. As sustainability assurance practices evolve internationally, including through ISSA 5000 where adopted, transparent boundaries, documented controls and clearly defined assurance scopes will remain important.

Strategic Implications for the Telecommunications Sector

StarHub's disclosures illustrate how sustainability issues within telecommunications extend beyond conventional corporate environmental management. Rising data traffic, network modernisation, cybersecurity risks and demand for reliable connectivity create interconnected operational and financial considerations. Energy efficiency can support both emissions reduction and operating cost management, while cybersecurity and network resilience underpin service continuity.

The company's climate scenario analysis identifies heatwaves, flooding and carbon pricing as relevant risks, reinforcing the importance of physical asset resilience. Meanwhile, supplier emissions highlight the influence of equipment manufacturers, technology providers and procurement decisions on sector-wide decarbonisation.

Emerging TNFD guidance for technology and communications also provides a potential avenue for assessing nature-related dependencies and impacts across infrastructure, energy systems and electronics supply chains. Such analysis would be an opportunity for further development, rather than an achievement already demonstrated by StarHub's 2025 report.

ESG Maturity and Future Positioning

StarHub demonstrates several characteristics associated with developing ESG management maturity: Board-level oversight, structured materiality assessment, quantified climate commitments, sustainability-linked remuneration and selected independent assurance. Its reporting increasingly connects sustainability considerations with operational risks and business priorities. The first standalone report also improves the visibility of disclosure boundaries, methodologies and performance challenges.

Nevertheless, maturity should ultimately be assessed through consistent implementation and measurable outcomes. Priority areas include reversing the Scope 3 emissions trajectory, strengthening supplier data, monitoring workforce retention, improving reporting coverage and maintaining robust digital security controls.

StarHub's future positioning will depend less on the expansion of sustainability commitments than on its ability to demonstrate that governance structures translate into sustained, comparable performance.

Pacifica ESG View

StarHub's 2025 Sustainability Report reflects an increasingly structured approach to ESG governance, climate management and digital infrastructure resilience. Its Scope 1 and 2 reductions, renewable electricity procurement and governance arrangements provide evidence of operational progress, while the Scope 3 target gap highlights the challenges of value-chain decarbonisation.

Workforce turnover, reporting boundaries and the limited scope of external assurance are additional areas requiring attention. Pacifica ESG considers supplier engagement effectiveness, emissions comparability and sustained operational outcomes particularly important indicators of the company's future sustainability maturity.

Implications for the Wider Market

StarHub's experience illustrates a broader transition in telecommunications sustainability management: from measuring direct operational impacts towards addressing value-chain emissions, infrastructure resilience, customer trust and human capital risks.

For investors, the distinction between reported achievements and target delivery is essential. For corporate sustainability leaders, the case highlights the importance of integrating procurement, risk management, financial planning and disclosure controls.

As ISSB-aligned reporting and sustainability assurance expectations develop, companies that demonstrate consistent data quality, credible transition execution and transparent reporting boundaries may be better positioned to respond to regulatory and stakeholder scrutiny.

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