Structured Digital Database

as required under SEBI (Prevention of Insider Trading) Regulations, 2015

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Why Structured Digital Database?

OBJECTIVES

  • SDD (Structured Digital Database) introduced by SEBI in order to build a mechanism to help investigate Insider Trading
  • SDD may prove to be a deterrent to Insider Trading

APPLICABILITY

  • Requirement was introduced by the SEBI w.e.f. April 1, 2019 and Amendments were introduced w.e.f. July 17, 2020
  • The board of Directors or head(s) of the organization required to handle Unpublished Price Sensitive Information (UPSI)
  • Listed Companies
  • Intermediaries
  • Fiduciaries

As per Law, SDD shall contain

Log of UPSI Transfer

Details of communication of identified Unpublished Price Sensitive Information (‘UPSI’)

Details of UPSI

Nature of UPSI and the purpose of which the UPSI was shared with the recipient

Identifiers of parties

PAN or other identifiers of the sender and recipient of UPSI to be stored

Audit trail

Date and time of making entries in SDD to be captured along with the actual date and time when the UPSI was shared. Audit trail to be kept.

What is treated as UPSI?

AS DEFINED BY SEBI IN ITS REGULATION ON INSIDER TRADING

“Unpublished Price Sensitive Information” means:

Any information, relating to a company or its securities, directly or indirectly, that is not generally available which upon becoming generally is to materially affect the price of the securities and shall, ordinarily including but not restricted to, information relating to the following:

  • Financial Results
  • Dividends
  • Expansion Of Business And Such Other Transactions
  • Restructuring i.e. Mergers, De-Mergers, Acquisitions, Delisting’s, Disposals
  • Change In Capital Structure
  • Changes In Management

Benefits of having an SDD

Sdd

Create and Maintain SDD in Tamperproof Database

Add Options

Add Designated Persons & Add Insiders

UPSI Data

Intimate Recipient of UPSI

Informations

Store Confidentiality of Information

Reports

Generate Reports

Audit Trails

Keep Audit Trails

Create and Maintain SDD in Tamperproof Database

  • Create and Maintain SDD with out software InSiDDer.
  • Period of not less than eight years after completion of the relevant transactions;

In the event of receipt of any information from the Board regarding any investigation or enforcement proceedings, the relevant information in the digital database shall be preserved till the completion of such proceedings.

Add data to SDD. All the data points prescribed by SEBI in its regulations have been covered.

  • Maintain a log of information on insiders for easy retrieval
  • Store confidentiality Agreements entered with the Insider
  • Nature of UPSI
  • Names of such persons who have shared the information
  • Names of such persons with whom information is shared with PAN or any other identifier

Audit Trail

  • Tamper Proof SDD
  • Date of creation and subsequent edits are recorded in History – Forms part of Audit trail

Automated Mails

  • When added as Insider / Designated Person
  • When UPSI Transfer is logged [ to the sender and Recipient ]

With inSiDDe₹ SDD you can:

insidersdd
  • Create And Maintain SDD In Tamperproof Database
  • Add Insiders
  • Add Designated Persons
  • Intimate Recipient Of UPSI
  • Generate Report. Keep Audit Trail

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