Control insider information and trading by designated persons

Record every sharing of unpublished price-sensitive information in the structured digital database, and compare designated persons' holdings from registrar data against trading-window closures and pre-clearances. The compliance officer can catch closed-window, contra and unreported trades and report code of conduct violations to the exchanges.

Starts when

Any unpublished price-sensitive information coming into existence or being shared, each quarter end, and any trade request or holding change by a designated person.

Runs: Continuous, with quarterly window closures.

People in the process

SSecretarialProcess Owner
FFinanceParticipating Team
LLegalParticipating Team
AAudit CommitteeParticipating Team
BBoard of DirectorsParticipating Team

The process is a starting point. The standards are yours.

Configure for the listed entity, instruments and applicable SEBI listing requirements. Materiality, disclosure timing and publication decisions remain with authorised reviewers.

Keep the work connected.

Secretarial

Assess and disclose material events to stock exchanges

Test each event reported by business units against the deemed-material list and materiality policy, logging when it became known and when it was filed. Secretarial can file complete exchange disclosures and show the board why each event was or was not disclosed.

BKLI

Secretarial

Approve related party transactions and track them against limits

Check each proposed related party deal against the related party list, arm's length pricing and cumulative materiality, then track actual transactions against approved limits. Secretarial can obtain audit committee and shareholder approval before commitment and file accurate half-yearly disclosures with the exchanges.

BFAB

Secretarial

Prepare and file quarterly financial results with stock exchanges

Coordinate the quarter close across subsidiaries, prepare standalone and consolidated results, and align the auditor's review and audit committee and board approvals with the exchange calendar. Finance and Secretarial can file approved results with the auditor's report immediately after the board meeting.

FSABI

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Order for the work. Room for the people.