Notification | Active
Purchase of assets of Marina at Keppel Bay by ONE15 Marina KB Pte. Ltd from Keppel Bay Pte Ltd.
2 March 2026
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Reference: | 400-140-2026-002 |
Notifying Party: | (a) SUTL Enterprise Ltd (“SUTL”) on behalf of ONE15 Marina KB Pte. Ltd. (“ONE15 Marina”); and (b) Keppel Bay Pte Ltd (“Keppel Bay”), |
Legal Representative(s): | Rajah & Tann Singapore LLP |
Notifying Date: | 13 February 2026 |
Summary of Transaction: | (i) the names of the merger parties; (a) ONE15 Marina KB Pte. Ltd. (“ONE15 Marina”)(“Purchaser”); and (b) Keppel Bay Pte Ltd (“Keppel Bay”)(“Vendor”) (collectively, the “Parties”). (ii) a description of the transaction; The notification relates to the proposed acquisition by the Purchaser of the property and assets at the Marina at Keppel Bay from the Vendor (the “Proposed Transaction”). (iii) a description of the business activities of the merger parties worldwide and in Singapore; ONE15 Marina KB Pte. Ltd. is a wholly-owned subsidiary of SUTL Enterprise Ltd (“SUTL”). SUTL is the only marina-focused business listed on the Singapore Exchange. SUTL’s activities comprise marina ownership and operations, marina development and consultancy, the ownership and management of marine industry events, as well as ancillary marine leisure services. The wider SUTL Group owns and operates ONE°15 Marina Sentosa Cove, a premium integrated marina offering wet berthing facilities and clubhouse amenities. Marina at Keppel Bay is operated and managed by Keppel Bay, which is a wholly-owned subsidiary of Keppel Ltd., a global asset manager and operator with operating capabilities in infrastructure, real estate and connectivity. (iv) a description of the overlapping goods or services, including brand names; Both Parties supply marina berths to customers in Singapore. The Purchaser trades under the brand names “SUTL Enterprise Ltd”, “ONE15 Marina Club” and “ONE15 Marina Sentosa Cove Singapore”, while the Vendor trades under the brand names “Keppel” and “Marina at Keppel Bay”. (v) a description of substitute goods or services from demand-side and supply-side considerations; On the demand-side, substitutes for the marina berths supplied by the Parties are the marina berths supplied by the Parties’ competitors (i.e. other marina operators in Singapore). On the supply side, there are no goods or services that might be considered as substitutes. The only substitutes for the supply of marina berths by the Parties are the marina berths currently supplied by the Parties’ competitors. (vi) the applicant’s views on: i. definition of the relevant market(s); The Parties submit that the relevant market should be defined as the market for the supply of marina berths in Singapore. ii. the way in which competition functions in this market; The Parties submit that the key drivers of competition in the market for the supply of marina berths in Singapore are the (i) quality of berths, facilities and services, (ii) location and accessibility of the marinas, (iii) berth availability and suitability, (iv) customer experience and service quality and (v) pricing of berthing options. iii. barriers to entry and countervailing buyer power; and The Parties submit that the barriers to entry in the market for the supply of marina berths include regulatory barriers and planning restraints from the Urban Redevelopment Authority, the costs of constructing marina berths, and the significant costs involved in acquiring foreshore leases from existing market players (given that there are limited foreshore leases allocated by the Singapore Land Authority). There are no other factors such as technology, R&D requirements, import restrictions and IP rights that would constitute a barrier to entry. The Parties submit that customers of marina operators hold significant countervailing buyer power as they can maintain berthing contracts with multiple marina operators depending on their requirements, and are also able to easily switch between different marina operators without any costs or significant delays (subject to berth availability). In some instances, customers have been able to negotiate for more favourable contractual terms or additional ancillary services to be provided. iv. the competitive effects of the merger (non-coordinated, coordinated and/or vertical and/or conglomerate effects, as relevant). Non-coordinated effects The Parties submit that non-coordinated effects will not arise from the Proposed Transaction as (i) the market will continue to be highly contestable, with only a small increment to the Purchaser’s market share, (ii) existing competitors have a high combined market share and continue to exert significant competitive constraints, (iii) customers have strong countervailing buyer power and (iv) there is a real and credible possibility of new entry by large international marina operators through acquiring other marinas in Singapore and/or developing new marinas. Coordinated effects The Parties submit that coordinated effects will not arise from the Proposed Transaction as existing market players face intense competition, and any hypothetical coordination would not be sustainable. Further, the market is highly differentiated as marina operators compete on multiple parameters, making it difficult, if not impossible, for market players to align conduct. Vertical effects The Parties submit that vertical effects will not arise from the Proposed Transaction as there are no vertical relationships between the Parties. Conglomerate effects The Parties submit that conglomerate effects will not arise from the Proposed Transaction as the Parties lack market power in related markets. Any potential conglomerate effects will be curtailed by the fact that existing competitors will continue to exert significant competitive constraints and that customers have strong countervailing buyer power. |
Consultation: | Interested parties are invited to submit their views on the Proposed Transaction. When submitting confidential information, interested parties should take note of the procedures outlined in CCS Guidelines on Merger Procedures.
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Supporting Documents | Interested third parties may request in writing to obtain more information on the Proposed Transaction. |