What information a listed company should maintain in its structured digital database as per Regulation 3(5) of the SEBI (Prohibition of Insider Trading) Regulation, 2015, in case the designated person is a fiduciary or i

As per Regulation 3 (5) of the SEBI (Prohibition of Insider Trading) Regulations, 2015, the board of directors or head(s) of the organisation of every person required to handle unpublished price sensitive information shall ensure that a structured digital database is maintained containing the nature of unpublished price sensitive information and the names of such persons who have shared the information and also the names of such persons with whom information is shared under this regulation along with the Permanent Account Number or any other identifier authorized by law where Permanent Account Number is not available. Such database shall not be outsourced and shall be maintained internally with adequate internal controls and checks such as time stamping and audit trails to ensure non-tampering of the database. Example: If the listed company has appointed a law firm or Merchant Banker in respect of fund-raising activity, it should obtain the name of the entity, so appointed, along with the PAN or other identifier, in case PAN is not available. The law firm or the Merchant Banker would in turn maintain its list of persons along with PAN or other unique identifier (in case PAN is not available), in accordance with Regulation 9A(2)(d) of the SEBI (Prohibition of Insider Trading) Regulations, 2015 and as required under Schedule C, with whom they have shared the unpublished price sensitive information.