Chapter 4

Due Diligence Guidelines –

Submission Readiness

4. Identifying Material Issues

4.1 Standards

When submitting an application on behalf of a listing applicant to the Stock Exchange, a sponsor should ensure that all material issues known to it which, in its reasonable opinion, are necessary for the consideration of:

(i) whether the listing applicant is suitable for listing; and

(ii) whether the listing of the applicant’s securities is contrary to the interest of the investing public or to the public interest;

are disclosed in writing to the Stock Exchange. [Paragraph 17.4(d) of the Code of Conduct]

4.2 Recommended Steps

The sponsor should review the listing application documents for compliance with the requirements of Paragraph 17.4(d) of the Code of Conduct and ensure that any material issues known to it are included in the listing application documents.


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.

Identifying Material Issues

Listing Applicant is Suitable for Listing

material issues included in the listing application documents

Paragraph 17.4(d) of the Code of Conduct

Hong Kong Securities and Futures Commission (SFC)

Hong Kong Stock Exchange

Suitability of listing applicant for listing

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