The only permanent, full‑time job I’ve ever had was at Ford Motor Company. I was there for just under a decade, and it was an incredible, open-eyed experience to see how the world works.
I worked on huge, complex technology systems that helped run global production lines. At the time, Ford had around 500,000 employees worldwide, and I was lucky enough to travel extensively as part of that role.
Very early in my career, one thing became obvious: IT is run very differently across the world.
There were differences even between the UK and US headquarters. In Germany, there were deep local traditions and ways of working that shaped how technology projects were run. In Spain, work revolved around the siesta — and you could buy beer from vending machines inside the office.
But beyond the anecdotes, the real challenge was language, culture, and how people actually worked together.
I spent close to a decade there. It set me up for life — and more importantly, it sparked the core interest that has shaped my entire career: different people work, live, and make decisions differently across the world.
Later, I saw this play out again when I worked at HP during the acquisition of Compaq. The cultural and operational differences didn’t disappear just because there was a deal. In fact, they became sharper. It was a lifetime education.
Decades later, I see the same pattern repeating in M&A — particularly in tech M&A.
The illusion of a single global M&A market
When you first enter M&A or corporate development, it’s easy to think of the market as fundamentally global.
Capital moves across borders. Technology scales internationally. Deals happen across the Atlantic all the time. It feels like you should be able to apply the same playbook everywhere.
But the reality is very different.
Local laws, traditions, and cultural expectations materially change how due diligence works. And if you ignore that, you don’t just miss risk — you damage your reputation.
Tech due diligence is a perfect example.
UK: Buyer beware
The UK operates firmly under a buyer‑beware (caveat emptor) model.
- The buyer carries the responsibility for discovering risk
- Sellers must not misrepresent, but disclosure is often reactive
- Warranties and indemnities allocate risk — they don’t uncover it
In practice, this means:
Independent Tech Due Diligence is essential. Buyers cannot assume sellers have identified or understood their own technical risks.
Tech DD in the UK is fundamentally about risk discovery.
United States: Buyer beware, amplified
The US takes buyer beware even further.
- Deep, aggressive due diligence
- Heavy focus on litigation risk
- Strong emphasis on cyber security, data, scalability, and IP
US buyers assume sellers optimise for presentation, not truth.
As a result, Tech DD is non‑negotiable and often highly specialised.
France: Seller disclosure
France operates under a seller‑disclosure regime.
Sellers have a positive legal obligation to disclose all material information they know. Failure to do so can invalidate contracts or trigger damages.
At first glance, this sounds like it should reduce the need for Tech DD.
It doesn’t.
Instead, Tech DD in France shifts focus:
- Validation of what has been disclosed
- Interpretation of technical risk
- Assessing what the seller may not realise is important
Disclosure tells you what the seller knows. Tech DD tells you what actually matters.
Germany: Structured, but still buyer‑led
Germany combines strong seller disclosure with highly formal processes.
- Heavy documentation
- Structured disclosure schedules
- Rigorous legal frameworks
Despite this, buyers still commission deep Tech Due Diligence.
Why? Because documentation doesn’t explain:
- Whether systems are fragile
- Whether teams can maintain what’s been built
- Whether the technology will survive post‑deal change
Nordics: High trust, high standards
Nordic markets often benefit from strong trust cultures and clean documentation.
But legally, they remain closer to buyer‑beware models.
Tech DD here tends to be:
- More collaborative
- Less adversarial
- Still essential for valuation and integration planning
Asia: Context matters enormously
Across Asia, the picture varies widely.
- Singapore and Hong Kong follow common‑law principles similar to the UK
- China places far greater reliance on due diligence to uncover operational and control risks
In many cases, Tech DD focuses less on code quality and more on operability, ownership, and execution risk.
The common thread
Even in seller‑disclosure jurisdictions, Tech DD never disappears.
Because:
- Sellers disclose what they know — not what they don’t understand
- Legal disclosure doesn’t equal technical interpretation
- Disclosure is backward‑looking; Tech DD is forward‑looking
Tech DD answers questions legal processes simply can’t:
- Will this scale?
- Will it break under growth?
- Is it maintainable without the founders?
- What happens on day one post‑acquisition?
Final thought
Working across jurisdictions requires far more than translating documents.
To be effective, you must understand:
- The law
- The culture
- The traditions behind how deals are done
And you must respect them.
Because in M&A — just like in global technology programmes — you always have a reputation at stake.
