Harbour Gate Capital Ltd sponsors an IPO priced on 5 May 2026. It has never covered the issuer, and no major event occurs. When may it first issue research on the issuer?
Paragraph 16.5(g) of the Code of Conduct bars a firm acting as manager, sponsor, listing agent or underwriter of a public offering from issuing investment research on the issuer within the 40 days immediately following the day the securities are priced for an IPO (10 days for a secondary offering). The exceptions, regular prior coverage or a major public event, do not apply. The period runs from 6 May to 14 June, the 40th day, so the earliest date is 15 June 2026. 14 June counts the pricing day as the first of the 40 days, 5 June applies 30 days, and 16 May applies the 10-day secondary-offering period. Source: SFC Code of Conduct (January 2026 edition) para 16.5(g) (as at October 2026).
Using the 10-day period, which applies only to secondary offerings, or counting the pricing day itself as day 1 of the 40.
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