The worst version of an investor relations job goes something like this. An analyst emails you a sharp question about a development at your own company — a contract that slipped, say, or a number that moved overnight — and the email is the first you’re hearing of it. Somewhere inside the building, three people have known for a week. You were not one of them. Now you have about forty minutes to find out whether you’re allowed to say anything, and what.
This is usually filed under “communication problems.” It is not. It’s an ownership problem, and it starts long before anyone drafts a release. Finance owns the numbers. The operating units own the developments, and legal owns the caution about saying any of it out loud. IR, whose entire job is to explain all of it to the market, tends to sit at the end of the queue, receiving information late, partial, and already framed by someone else.
The textbooks are great on being transparent with investors. They are quieter on the more awkward question underneath it: whether IR has anything reliable to be transparent with.
Access is not the same as information
The standard advice is that the IRO needs access to the C-suite. True, and not enough. Access is a chair in the room. Information is a flow into the job. People mix these up constantly.
The structural reason is that IR usually reports into the function that owns the data. The IRO answers to the CFO or the treasurer, and the CFO’s grip on the relationship has only tightened. McKinsey’s 2018 global survey of CFOs found 46% had become the main point person for investor relations, up from 33% two years earlier, and KPMG has put the share of CFOs “significantly involved” in IR at 65%. As a reporting line, fine. As an information architecture, less fine, because it quietly turns IR’s claim on the data into something the CFO grants rather than something the company guarantees.
And this is not a junior conduit you can afford to keep in the dark. Brown, Call, Clement and Sharp, in a 2019 Journal of Accounting and Economics paper built on a large survey of IROs and direct interviews, found that IR officers materially shape what gets disclosed and how, especially in private conversations and around earnings calls. A function with that much influence, running on stale information, is not a tidiness issue. It’s a disclosure issue.
In Asia, it’s also a disclosure problem
Here is the part that should make a CFO sit up, because it moves the whole conversation from “good practice” to “regulatory exposure.”
In Hong Kong, disclosing inside information (broadly, information that isn’t public but would move the share price if it were) is a statutory duty under Part XIVA of the Securities and Futures Ordinance. The wording is the interesting bit. The obligation bites “as soon as reasonably practicable after the inside information has come to the knowledge of the corporation,” and the SFC’s guidelines expect you to run internal systems that carry material information to the people who handle disclosure, while also locking it down on a need-to-know basis. Singapore runs a parallel timely-disclosure duty under SGX Listing Rule 703; Indonesia does the same through OJK Regulation POJK 31/2015.
Read the Hong Kong phrase again. The clock starts when the information reaches the corporation’s knowledge, which in practice means when it reaches the people who decide what to announce. So a company whose material news sits inside finance, or with the controlling shareholder, and reaches the disclosing function late, doesn’t just have a slow internal memo. It has a controls gap a regulator can point at. The same internal wiring that decides whether IR hears things early is the wiring the company gets judged on if it discloses late.
Put bluntly: internal gatekeeping is not a private inefficiency you get to keep to yourself. In three of Asia’s main markets, it’s a line item in your disclosure risk.
Why this bites harder in family-controlled markets
The implied company in most Western IR writing is widely held, professionally run, with a finance team that treats disclosure as routine plumbing. That is not the typical listed company in Hong Kong, Singapore, or much of Southeast Asia.
Across the region, ownership is concentrated, founders and families keep operational control, and the CFO often sits closer to the controlling shareholder than to the capital markets. Information in that setup tends to travel vertically, up to the owner and back down as instruction, rather than sideways across functions. IR is a sideways function by nature, so it tends to sit outside the channel that actually carries the news.
The evidence here is suggestive, and it’s worth being honest about where it comes from. The most-cited finding is American, not Asian: Chen, Chen and Cheng, studying S&P 1500 firms in the Journal of Accounting Research, found that family firms disclose less than non-family firms, and put part of it down to the family’s own superior access to information. The owners are already inside the information, so the firm shares less of it with everyone else. That’s US data, and the habit of stretching it onto Asia’s family markets is reasonable but should be labelled, not smuggled. The extrapolation isn’t a wild one; Asian ownership is, if anything, more concentrated, and family firms are commonly estimated at around 70% of listed companies in markets like Malaysia (a figure traced to Amran and Ahmad’s 2010 study, though it moves with how you define “family firm”). Supporting work on ownership concentration and information asymmetry, including in Asian markets, points the same way.
But notice what the finding actually describes. When the people who own the company also own the information, less of it flows outward: to the market, and to the function standing on the outward side of the wall. That function is IR. The disclosure symptom academics measure is the external face of an internal fact.
The number lives with the owner, and it doesn’t travel.
The fix exists, but it’s usually installed at half strength
The cure is not a feistier IRO willing to fight for scraps. It’s structural, and it has a name you already know: the disclosure committee.
Done properly, it puts corporate counsel, the principal accounting officer, tax, internal audit, the operating units and IR around one table to review what goes out before it goes out. The value isn’t the approval stamp. It’s that material information now has to pass through a standing channel on which IR has a seat by right, not by the CFO’s goodwill.
The catch — and most companies walk straight into it — is that IR often gets seated as, in the polite phrase, “an observer of the messaging.” Present to check the tone, absent from the decision, handed the conclusion rather than the development. EY’s work on disclosure-committee practice makes the point that what matters is who’s genuinely in the flow of information, not who’s in the room. Seat IR as a proofreader and you’ve rebuilt the original problem inside a governance structure and given it a nicer letterhead.
Putting ownership of the number on purpose
The structural fix
- Stand up a disclosure committee with real authority. Bring corporate counsel, the principal accounting officer, tax, internal audit and the operating units to one table that reviews material information before it goes out, and meets at least quarterly, more often around results.
- Give IR a substantive seat, not an observer’s. A proofreader who checks tone after the decision is made recreates the original problem. IR needs to see developments early enough, and in enough detail, to read them the way an investor will.
- Feed the channel early. Route material developments to the disclosing function as they emerge, not once the framing is set. In Hong Kong, Singapore and Indonesia, the clock that matters starts when the company knows, not just the owner.
This is the reform we most consistently put in front of clients — across EMEA for years, and now in Indonesia — because it changes who owns the number without asking the company to restructure anything else.
Not sure whether material information actually reaches your IR function in time, or only after the framing is set? Book a disclosure diagnostic (20 minutes, no obligation) and we’ll map who owns your number, and when it moves.
What good IR information flow looks like
Three quick tests tell you whether information actually reaches IR, or whether IR is just tolerated near the room.
The first is timing. Does IR learn about material developments while there’s still room to prepare, or only after the framing has set? If the briefings are always late, the architecture is broken no matter how senior the IRO, and in Hong Kong, Singapore or Indonesia a late internal flow can quietly become a late external one.
The second is completeness, and it’s the one most often fudged. Giving IR the headline number is not the same as giving IR the build. Hand someone a finished figure and they can’t anticipate the questions it will provoke; let them see how it was assembled and they know exactly where the soft spots are.
The third is consistency between the internal and external stories. Employees are vigilant readers of everything the company says in public, and when the staff version and the investor version drift apart, the gap shows up fast. At that point it stops being a messaging problem and becomes a credibility one.
So what?
There’s no single correct answer to who should own information inside a company. Ownership structures differ, finance cultures differ, and an architecture that suits a widely held Singapore bank won’t transplant cleanly onto a founder-run Indonesian conglomerate. Companies should expect to design their own version rather than copy someone else’s.
But “there’s no universal answer” is not a licence to leave the question unasked, and this is the part worth holding onto. The worst outcome isn’t an imperfect ownership model. It’s no deliberate model at all: information moving by habit and relationship, IR finding out last, and the company discovering the gap only when a disclosure lands late or the public story doesn’t line up with the private one.
IR can’t be better than the information it gets. So before spending on sharper messaging, better materials, or another roadshow, answer the cheaper question first: does the function responsible for your equity story hold a reliable, deliberate claim on the data behind it? In a lot of companies, and disproportionately in Asia’s owner-controlled ones, the honest answer is no. That isn’t a communications project; it’s a governance decision about who owns the number, and when it’s allowed to move. Make it on purpose, give it a structure, put IR inside it, and the messaging mostly takes care of itself.
Frequently asked questions
Who should be responsible for disclosing material information in a listed company?
Responsibility belongs to a cross-functional disclosure committee — typically corporate counsel, the principal accounting officer, finance, internal audit and investor relations — not to any single function. The committee reviews material information before release and gives IR a standing seat in the process rather than a late, advisory one.
What is a disclosure committee and why does it matter?
A disclosure committee is a standing internal body that reviews a company’s material disclosures before they are published. It matters because it creates a formal channel through which information must pass, so the people who explain the company to the market see material developments early enough to handle them well.
Does Hong Kong law require companies to disclose inside information quickly?
Yes. Under Part XIVA of the Securities and Futures Ordinance, a Hong Kong-listed company must disclose inside information as soon as reasonably practicable after it has come to the corporation’s knowledge, and must keep internal controls that move that information to the people responsible for disclosure. Singapore (SGX Rule 703) and Indonesia (OJK POJK 31/2015) impose comparable timely-disclosure duties.
Why is internal information flow harder in family-controlled companies?
In concentrated, family-controlled businesses, information tends to travel vertically to the controlling owner rather than horizontally across functions. Research on family firms finds they disclose less, partly because the owners already have the information — which can leave investor relations, and the market, on the outside of it.
Advising listed companies representing over $50 billion in aggregate market capitalisation.
If your IR team is consistently the last to know, the problem is structural, and fixable. A 20-minute disclosure diagnostic, no obligation — you’ll leave with a one-page picture of where your information stalls and who needs to be in the room.
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