Chapter 9

Due Diligence Guidelines –

Interviews of Major Business Stakeholders

5. Establishing the Identity and Authority of Interviewees

5.1 Standard

In conducting interviews, the sponsor should: … (iii) confirm the bona fides of the interviewee (including establishing the identity of the interviewee and other relevant information) to satisfy itself that the interviewee has the appropriate authority and knowledge for the interview; [Paragraph 17.6(f)(iii) of the Code of Conduct]

5.2 Recommended Steps

5.2.1 The listing applicant should guide the sponsor as to the names and titles of the persons with knowledge of the listing applicant’s relationship with each business stakeholder to be interviewed by the sponsor.

5.2.2 The sponsor should seek to verify independently the identity and position of the person to be interviewed – e.g., through information contained in annual reports of the relevant company, an email from a company address, obtaining a business card, on the basis of customary ID documentation such as an ID card or passport, or a check of available information on the interviewee’s employees. However, it is acknowledged that third party interviewees are under no compulsion to cooperate with the interview process and may refuse to make personal documents (particularly ID cards and passports) available, on the grounds of such materials being personal, without this of itself raising reasons to question their bona fides.


If the sponsor intends to keep a copy of any ID document, it should follow procedures designed to ensure compliance with relevant provisions of the Personal Data (Privacy) Ordinance (Cap. 486 of the laws of Hong Kong).

5.2.3 Where the sponsor contacts the person to be interviewed through an address or telephone number provided by the listing applicant, the sponsor should seek to verify the address or telephone number provided. For example, where the sponsor conducts an interview by telephone, it is preferable for the person to be contacted through a general telephone number of the relevant entity and not via a personal direct line, home or mobile telephone number.

5.2.4 If, during or after an interview, it becomes apparent that the person lacks sufficient authority or knowledge regarding the third party’s dealings with the listing applicant, the sponsor should arrange a further interview with a more appropriate person.


HKCFEF Limited and the contributing law firms, accountants and sponsors are not offering these due diligence guidelines as legal, financial or professional advice or services and they should not be relied upon as such. These due diligence guidelines should not be used as a sole basis for any decision, action or inaction and are not meant to serve as a substitute for the advice of qualified professionals. See here for the full terms and conditions.

Business Stakeholder Identity in Due Diligence Process

Identity and Authority of Interviewees

Listing Applicants Relationship with Business Stakeholder Interviewed

Establishing the Identity and Authority of Interviewees

Confirm Bona Fides of Interviewee

Lack of Sufficient Authority or Knowledge Regarding Third Party’s Dealings

Personal Data Ordinance

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