The Hong Kong Stock Exchange’s listing agreement says:

In addition to the information set out in Appendix 1A, a Mineral Company must include in its listing document……if relevant and material to the Mineral Company’s business operations, information on the following:—

(c) compliance with host country laws, regulations and permits, and payments made to host country governments in respect of tax, royalties and other significant payments on a country by country basis;

Note the reference to country-by-country reporting. I stress, the data referred to here is on past performance. There is a separate requiremnt that these payments also be projected.

Glencore’s Hong Kong prospectus was issued today.

The data referred to above is not included in it as far as I can see. I’ve searched it each and every way I can.

There is some projected data  - but on tax it simply discloses statutory tax rates in most cases. But of country-by-country reporting of past data there is not a hint.

In that case does this disclosure comply with Hong Kong’s listing requirements? Would anyone like to suggest how that can be the case?

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