Worldwide: Australia IPO Series – Part 3: Where To IPO Your Company - Comparing The Key Global Exchanges

For companies with an international profile, the ASX isn't the only exchange on which they can list. Other exchanges may be more suitable, depending on where the company carries on business, the sector it is in and the valuation it can obtain for its business.

A brief summary of some of the key attributes of each exchange is set out below.

United States

The key exchanges in the United States are the New York Stock Exchange and Nasdaq. Listing on these exchanges gives issuers direct access to the enormous US capital market.

Both the NYSE and Nasdaq are broken into a number of separate markets which all have their own different admission requirements, which are, generally speaking, significantly more demanding than the admission requirements for the ASX. The profit and market capitalisation requirements are substantially higher than those on the ASX.

The New York Stock Exchange is more suitable for larger mature companies, whilst the requirements of Nasdaq are more flexible and the exchange often attracts companies in the earlier stages of operation. The Nasdaq exchange is famous for the listing of technology companies.

A new exchange has recently entered the market place- the IEX, or Investors Exchange. This exchange focuses on ease and transparency of operation and lower listing fees, however is more focussed on enticing listed companies to switch exchanges at present rather than IPO's.

Listing on US exchanges brings with it the need to comply with some of the most onerous corporate governance and anti-corruption requirements known. The penalties for breaching these requirements are substantial and company boards need to educate themselves as to the requirements prior to the listing occurring.

Hong Kong

The Hong Kong Stock Exchange is a renowned international exchange which provides access to the mainland China and Asia capital markets generally. The exchange includes a main board and a second board (the Growth Enterprise Market or GEM).

The requirements for listing on the main board are again more challenging than ASX requirements and a sponsor is required. GEM requirements, while less, are still significant with the requirement for a sponsor and compliance with a strict disclosure regime.

The exchange is attractive to international investors and around half of the funds raised in recent years have been raised by international companies. The exchange is perceived by some as allowing clients to achieve better business valuations.

However the time that needs to be taken to prepare a company for a listing is often longer than for other exchanges, and international companies need to satisfy a number of conditions to ensure they achieve equivalence in regulation to local companies before they can list.

The Hong Kong exchanges are working hard to improve their attractiveness to technology companies wanting to list.

Singapore

The Singapore Stock Exchange gives issuers a chance to list in a business friendly, low tax environment. The exchange is particularly attractive to foreign issuers and has many listed companies in the resource and energy, commodities, real estate and maritime industries.

The market is well regulated and attracts a lot of fund money given a number of large funds are domiciled in the city.

The exchange has a main board and a second board known as "Catalist" which attracts earlier stage companies with high growth.

The requirements for an SGX main board listing are also more onerous than the ASX, although the escrow or lock- up periods are generally not as long.

The Singaporean exchange is perceived to be in competition with the Hong Kong exchange to some extent, with Hong Kong seen by some as providing more direct access to China.

London

The London Stock Exchange is one of the largest and most famous markets in the world. The exchange includes a main board which hosts some of the world's largest companies, and a second board known as AIM. The listing requirements for both markets are generally not as onerous compared with other exchanges, although the costs associated with the listing process can be high.

The AIM market generally attracts earlier stage growth companies and has a relatively straightforward listing regime, although a NOMAD (licenced nominated advisor or sponsor) is required which supervises the listing process.

The exchange attracts businesses in a wide range of sectors, including energy and resources, technology stocks and industrials. Many geographies are also represented, including regions as diverse as the Middle East, Africa and the CIS

Canada

The main Canadian exchange is the Toronto Stock Exchange. It comprises a main board and a secondary board known as the TSX Venture Exchange (TSXV). The exchange is famous for the listing of resources and energy companies.

The listing requirements for a main board listing are similar to those for the ASX. The requirements for listing on the TSXV are not onerous, however a sponsor is usually required.

Dual Listings- Australian Companies

Australian companies listed on the ASX often raise capital offshore in markets like the United States and the United Kingdom. Sometimes these capital raisings are associated with a secondary listing on an offshore exchange like the London Stock Exchange or Nasdaq.

Any offerings must be compliant with the securities offering laws in the country in which the securities are offered. Depository receipts are again common (for example, American Depository Receipts or ADR's for US exchanges and GDR's or global depository receipts for European exchanges). However, care needs to be taken when contemplating an offshore listing. The listing and compliance costs can be significant, and such action can expose the company to a raft of onerous reporting, governance, sanctions and anti- corruption type laws applicable in the offshore jurisdiction. The concept needs to be thought through prior to proceeding and the pros and cons carefully assessed.

Dentons has offices in almost all of the key financial centres around the world, with capital markets experts who can advise on process for and ramifications of offering securities in these key markets.

A comparison table of the listing requirements for the major global exchanges is available on request.

This is the final part of our IPO series. If you want to know 'What to consider before you list on the ASX?' click here. If you want to know 'The listing process for an IPO' click here.

Dentons is the world's first polycentric global law firm. A top 20 firm on the Acritas 2015 Global Elite Brand Index, the Firm is committed to challenging the status quo in delivering consistent and uncompromising quality and value in new and inventive ways. Driven to provide clients a competitive edge, and connected to the communities where its clients want to do business, Dentons knows that understanding local cultures is crucial to successfully completing a deal, resolving a dispute or solving a business challenge. Now the world's largest law firm, Dentons' global team builds agile, tailored solutions to meet the local, national and global needs of private and public clients of any size in more than 125 locations serving 50-plus countries. www.dentons.com.

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