SDD, Insider Trading Compliance Software
Structured Digital Database (SDD), Designated Persons, Employee Trading for SEBI Compliances.
Affinis is a family of applications for Listed Entities and Intermediaries to manage and automate compliance with SEBI (Prevention of Insider Trading) Norms.
Prevention of Insider Trading – The Complete Software Solution for Compliance
Structured Digital Database to seamlessly and automatically capture the flow of UPSI with details of senders, receivers and entities.
Employee Trading and Tracking to track & manage employee holdings & trades – review, approve, report & verify.
Insider Designated Database to maintain details and code compliances of Designated Persons under the SEBI (PIT) regulations.
Structured Digital Database (SDD)
A state-of-the-art application to help organizations maintain their own Structured Digital Database in compliance with SEBI Prevention of Insider Trading Norms for Listed Entities & Intermediaries.
SDD that enables single click capture for every detail – senders, receivers, entities and the UPSI itself.
Reduce duplication of effort, operational burden and overlaps in compliance with the SEBI SDD requirements.
Auto-Capture just the UPSI mails you want into the SDD seamlessly. No CC’ing and no additional steps.
Create bespoke grouping of people in your Structured Digital Database; the Board or the Ops teams.
Our Structured Digital Database solution supports configurations for multiple entities, IDs, UPSI or communication types.
Structured Digital Database that is Internal, Secure, Controlled, Auditable and Time-Stamped.
Natural flow for internal or external sharing of Unpublished Price Sensitive Information- persons or entities.
Data remains within your control, actual UPSI in email never goes to the Structured Digital Database.
Core for small teams managing Compliance centrally, Prime for more complex requirements.
Use code names to protect UPSI, quicken information capture, slotting and referencing for security cum convenience.
Employee Trading & Tracker (ETT)
An advanced and intuitive application for organizations to maintain compliance with Insider Trading regulations; close trading window, maintain sensitive lists, collate and track holdings or employees and connected persons. Employees have independent logins to submit information, request approvals, track status and log their trades.
Compliance Officers can trigger and collect Statement of Holdings for all or specific individuals and get intimated for exceptions.
Employee Trades executed within approved parameters are continuously and automatically updated.
Employee Personal Trading Compliance boosted by independent login to submit holdings, view and update.
Employees can request personal account trading approvals for self or connections in one screen, directly and easily.
Affinis(ETT) enables Compliance Officers to automatically deal with requests and verify trades logged by employees.
Listed entities can close trading window as per Insider Trading regulations, send intimations with a single click.
Upload Beneficiary Positions from DPs for independent verification with integrated exception management.
Trigger request for security holdings of employees; for self, family and Material Financial Relationships.
Employees can use ISIN based inputs to easily reflect demat holdings instead of entity names, security types, series, etc.
Affinis(ETT) empowers employees to check approval status and log execution of approved trades independently.
Insider Designated Database (IDD)
A structured and streamlined application for organizations to manage regulatory requirements around Designated Persons and persons connected to these Designated Persons for the purposes of compliance with Prevention of Insider Trading regulations.
Ease the identification process for Designated Persons; get a list of potential DPs per regulations to finalize.
Identify and maintain a list of all entities with special status; Material Subsidiaries, Intermediaries, Fiduciaries.
Send Notice of Compliance Obligations for Code of Conduct with one-click, evidence with reports of trail.
Record and demonstrate rationale and timing for DP identification; confidential Compliance notes for record.
Designated Persons can directly enter contact, education, professional and other details for self of connections as applicable.
Compliance Officers can configure content of notice of compliance obligations or code of conduct.
Affinis Is Intuitive, Seamless, Secure, Easy
Organizations have complex needs. The struggle to balance secure access, ease of use, rapid entry, ease of configuration and cost of deployment is challenging.
In addition, multiple functions or roles, individual users and the ‘Need-to-Know’ associated with them all present further challenges.
Affinis is geared to solve all these problems even as Insider Trading Compliances continue to grow in scope and complexity.
Central Control Panel
Cross-integrate data. Cross-leverage controls. Manage policies. Align your corporate structure.
Whether it relates directly to Insider Trading or to your organization or your corporate group, Affinis has you covered with a central command module that feeds into and enables all modules.
Works the Way Business Does
Control functions, compliance and regulated employees have specific access types to align with their priorities.
With deep access to data, reports and configurations for Compliance, independent access to HR to populate people data and input-based access for Designated Persons, Affinis is designed to balance real world risks and controls with ease and convenience to manage Insider Trading risks.
The flow of Inside Information and UPSI often does not respect your convenience.
Access Affinis through fully responsive design accessible across multiple browsers on any operating system, on your laptop, tablet, cellphone or anywhere your intranet is accessible.
Role Based Access
Employees play many roles – as an employee, as a Compliance Officer, as a supervisor or as an admin.
Affinis is designed to fit, align and even smoothen all the roles you play. Set Insider Trading Compliance rules as Compliance or Company Secretary, comply with them as an employee or approve compliance requests from your reportees.
Integrates Seamlessly in Your Environment
Server based deployments enable all employees access to Affinis securely within your environment through a browser.
Individual installations on each device not required, improving convenience, security, control and costs.
Multiple Actions In One Go
Sometimes, a screen-by-screen effort does not work when volumes are high.
Simply download readily available formats, fill and upload back on the same screen. Most importantly, all checks and controls remain in place upon uploading, giving you the best of both worlds.
You should not need us to maintain your own policies.
Independently maintain your policies whether related to Insider Trading or otherwise, choose structures that work best for you, create your own one-click entries, and enable or disable options organizationally.
More than a software application, AFFINIS IS YOUR INSIDER TRADING COMPLIANCE CENTER
In today’s corporate structure, everything connects together; entities or people, internal or external, listed entities or intermediaries, auditors or Company Secretary and security types or ISINs.
- A Structured Digital Database or Designated Person database or Employee Trading Tracker that maintains information separately instead of contributing to each other causes duplication, friction and wasteful effort.
- A solution walled off from your emailing system creates silos and duplications and leads to errors.
- AFFINIS integrates, leverages and enhances your compliance results even as it massively reduces your compliance efforts.
Spare the regulation and you spoil the corporation.– C.A.A. Savastano
Insider trading intelligence dashboards, by Date, Project, Person, Status, Security or ISIN.
Keep private information restricted. Only specifically authorized risk functions get access.
FAQs, Screen-tips and Guidance at your fingertips every step of the way.
What kinds of UPSI needs to be captured into the Structured Digital Database?
The Securities and Exchange Board of India (Prevention of Insider Trading) Regulations 2015 (SEBI Regulations), as amended from time to time, provide indicative guidance. However, simply put, any information transmitted over any channel or media that is not yet made public and has the potential to impact the share price of listed securities must be treated as UPSI. All identified UPSI can be quickly and easily entered into Affinis(SDD).
What is the implication of information being treated as UPSI?
Trading of Shares of a Listed Company using UPSI is strongly prohibited and holds numerous fines and penalties including imprisonment. All flow of UPSI must therefore be logged into a Structured Digital Database like Affinis(SDD).
What if I held UPSI but that was not the reason I traded?
From a regulatory perspective, it may be presumed that if you hold UPSI, your trade is motivated with awareness of UPSI. As such, it is important to log any flow of UPSI into Affinis(SDD) or take approvals for trading via Affinis(ETT).
What is the connection between the aforementioned Structured Digital Database and UPSI?
SEBI has required entities that exchange UPSI to maintain multiple details for each instance of UPSI shared and received on a continuing basis in a ‘Structured Digital Database’ (SDD) like Affinis(SDD). These details include Senders and Recipient Name and Identification Details, Senders and Recipient’s Organizations and Identification Details, Date and Time of Sharing UPSI, the Listed Entity that the UPSI Pertains to and the Nature of UPSI.
What else should I know about the regulatory requirements on maintaining a Structured Digital Database?
Non-maintenance of SDD is considered a contravention of the Insider Trading Regulations, with complete rights to deal with any such contraventions retained by SEBI. Non-maintenance, incomplete maintenance, outsourcing, lack of time stamping, maintenance on alterable media, incomplete or delayed availability of required information etc all considered non-compliance. Affinis(SDD) is a system that would be considered fully compliant with all SEBI requirements.
Where is the data and records in the Structured Digital Database maintained? Can anyone else access the information in Affinis?
The Securities and Exchange Board of India (Prevention of Insider Trading) Regulations 2015, as amended from time to time, requires that the structured digital database shall not be outsourced and shall be maintained internally with adequate internal controls and checks. In fact, even databases/ servers provided by third party vendors will be considered as outsourced whether within India or outside India. Thus, any Structured Digital Database maintained on, say, Amazon, Google or cloud servers, will be considered as outsourced and therefore prohibited as clarified by the Comprehensive FAQs on SEBI (PIT) Regulations, 2015. Affinis(SDD) is fully compliant with all SEBI requirements and only authorized people have access to it on your internal systems.
Can I simply upload a pdf of an email containing UPSI into a Structured Digital Database?
No. The obligation is to maintain the Nature of UPSI, not UPSI itself (the later may increase the risk rather than reducing it). A pdf of an email would have the actual UPSI while at the same time it would not be linked to PAN and Entity details of the individual. As such, no uploads are possible other than as provided for in compliance with the requirements. Affinis(SDD) is therefore designed to prevent this and promote secure, quick and easy data entry instead.
Why can we not simply maintain the UPSI and other information in an excel sheet?
The UPSI data is required to be kept recorded by maintaining a structured digital database which provides time stamping and internal controls & checks, a critical one being non-tamperability. These features would not be viable in Microsoft Excel or any other regular spreadsheeting software given the lack of internal controls and checks, lack of audit trail and the high tamperability of data. One of the reasons Affinis(SDD) is considered compliant is because it provides secure audit trails, anti-tamperability and time-stamping.
What additional features are available in Affinis(SDD)’s Prime variant over Core?
In addition to all features of the Core variant, Prime has four major additional features for organizations with more complex needs – (1) Prime enables creation of multiple “Chinese Walls”, permitting different deal teams within the same entity to manage projects privately (Compliance Officer always has access to all information) (2) With Prime, one can seek and record approvals from supervisors for policy maintenance updates (3) Delegatees can seek and record approval from UPSI senders or receivers within Prime before committing entries (not applicable for UPSI entries recorded via email auto-capture) (4) Prime provides additional email notifications, reminders, data intelligence reports as well as UPSI ‘super-grouping’.
What are Gray Lists or Restricted Lists?
A Restricted List is typically refers to a list of stocks that are ineligible for trade, either themselves or via any other person or third party. It does not necessarily imply that they are risky or flawed in any way, but are nonetheless prohibited on account of Personal Account Dealing restrictions or Employee Personal Trading Compliance requirements. Affinis(ETT) enables maintenance of Grey and Restricted Lists logically and easily.
What is a Statement of Holdings in the context of Insider Trading compliances?
A Statement of Holding refers to a summary of all securities held by you in your Demat account as on a particular date. A request to submit the Statement of Holdings can be triggered by the Compliance Officer through Affinis(ETT). Designated Persons can independently login and submit these statements.
What is a Material Financial Relationship?
It typically refers to a relationship in which one person has significant financial dealings in their relationship with another, for example, when he/she is a recipient of any kind of payment (loan or gift) during a specified period immediately preceding and which amount is equivalent to at least a specied fraction of annual income. Relationships in which the payment is based on arm’s length transactions are typically excluded. Based on the rationale applied, Material Financial Relationships can be recorded in Affinis(IDD) by each employee along with rationale if needed.
What is BENPOS?
Benpos or Beneficiary Position is a statement of securities held by a person (who is typically identified by the PAN), as on a particular date and is maintained by Depositories such as CDSL/NSDL independent of the company or the beneficiary. Such statements can be uploaded to Affinis(ETT) for independent verification. Exceptions can be managed or tracked from within Affinis(ETT) itself.
Who is a Designated Person?
Designated Person(s) under the SEBI Prevention of Insider Trading Regulations is an inclusive definition. Illustratively, under the regulations, it includes various persons and roles such as promoters; directors; key managerial personnel; auditors; all employees and support staff of various departments such as Accounts, Finance, Legal, Internal audit, Information technology and Secretarial Department.
It also includes Key Managerial Personnel of the material subsidiary of the Company; Secretaries/EAs reporting to the Directors and the Key Managerial Personnel; all Departmental Heads of the Company as well as employees upto two levels below the Board of Directors of the Company.
In addition, other persons may be identified by the Compliance Officer as well. Affinis(IDD) assists in identifying the list of persons who may potentially qualify as Designated Persons to more logically and formally record and maintain the list. The list of Designated Persons is also used to manage Designated Person compliances. Affinis(IDD) maintains an evidentiary trail of notices of compliance obligations and provides reports as required.