Notes on dealing disclosures

We collect disclosures of interests of directors and chief executives in listed company shares from the statutory filings published here in accordance with the HK Securities and Futures Ordinance (SFO). We aim to produce a more user-friendly version, by:

  1. That last part is our secret sauce, because names are often inconsistent - the Stock Exchange does not use a unique identifier for individuals. Using a proprietary algorithm we can match more than 99% of them, and the last few we do manually.
  2. New filings are normally published at 5pm each day, and we aim to update our database with automatically within 15 minutes of that.
  3. The SFO came into effect on 1-Apr-2003. Before that, there was the separate Securities (Disclosure of Interests) Ordinance, but filings were paper-based and are not machine-readable, so we don't cover those.
  4. "Interests in shares" includes derivative interests, such as options and futures contracts, call or put, long or short.
  5. We show short interests as negative holdings and negative percentage stakes. A reduction of a short interest is therefore a positive number.
  6. If the director discloses an on-exchange highest price or average price but fails to disclose the other, then we assume that they are the same.
  7. The law does not require disclosure of the price for short transactions, so you will see grey boxes in those columns.
  8. Filings must be made (or at least, sent) within 3 business days of the transaction. By amendment to the SFO, Saturday was excluded as a business day from 4-May-2012 onwards. There is a time lag between a director making a filing and it being published, typically of one business day, but sometimes longer.
  9. Because the forms are so complicated to complete and require filers to use numeric codes looked up from other documents, the filers often make errors and/or omissions which are never corrected, so you will find inconsistencies and contradictions, such as a shareholding increasing on something tagged with a disposal code, or decreasing on something tagged with an acquisition code.
  10. Another common error occurs when a director doesn't include his derivative interests (usually share options) in the total number of shares in which he is interested. So when he exercises an option and the shares are issued to him, the total goes up, whereas in fact he was interested in those (unissued) shares all along.
  11. Filings have, on some rare occasions, been replaced with new filings to correct errors. Therefore it is possible that filings we have collected are no longer valid. If in doubt, click on the link marked "filing" to see the original published filing, if it still exists.
  12. The original filings also show the breakdown of derivative interests (such as a director's share options) and the composition of corporate shareholders in which the director holds at least 1/3 of the voting rights (including pyramids of companies in which each company owns at least 1/3 of the votes in the next one down).
  13. If you spot an error, please tell us.
  14. For general FAQ on Webb-site Who's Who, click here.

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