A legal memorandum asserts that international law places due diligence obligations on the Singapore Exchange (SGX) concerning the listing of Emerging Towns & Cities Singapore (ETC), the developer of the Golden City complex in Myanmar, under a build-operate-transfer agreement with the Myanmar Army’s Quartermaster General’s Office (QMGO). The memorandum states that "ETC and SGX should avoid causing or contributing to adverse human rights impacts through their own activities, or activities linked to their business relationship, regardless of the multiple links in the supply chain of their funding for Golden City.”

Business and Human Rights Resource Centre invited SGX and ETC as well as RHT Capital Pte. Ltd (RHT) [which is also cited in the memorandum for its alleged sponsorship of ETC in its listing on the SGX] to respond to the memorandum. SGX's response is linked below. ETC and RHT did not respond.