The listed company should maintain structured digital database internally, which shall
contain information including the following:
(i). Details of the Unpublished Price Sensitive Information (UPSI);
(ii). Details of persons with whom such UPSI is shared (along with their PANs/other unique
identifier) and details of persons who have shared the information.
Similarly, another structured digital database should be maintained internally by fiduciary or
intermediary, capturing information as mentioned above at point (i) and (ii), in accordance with
Regulation 9A (2)(d) and as required under Schedule C.
For example: The listed company (X) has appointed a Law firm or Merchant Banker (Y) in
respect of fund raising activity and (A) from listed company has shared the said UPSI with (B)
of Law firm or Merchant Banker. The structured digital database of (X) should capture the
nature of UPSI shared, details of (A), (Y) and (B), along with their PAN or other unique identifier (in case PAN is not available). The Law firm or the Merchant Banker (Y) shall in turn maintain another structured digital database internally capturing the nature of UPSI received/shared, details of (X), (A) and (B) along with their PAN or other unique identifier (in case PAN is not available), in accordance with Regulation 9A(2)(d) and as required under Schedule C
The listed company should maintain the names of the fiduciary or intermediary with whom they have shared information along with the Permanent Account Number (PAN) or other unique identifier authorized by law, in case PAN is not available. The fiduciary/ intermediary, shall at their end, be required to maintain details as required under the Schedule C in respect of persons having access to UPSI. For 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not available), in accordance with Regulation 9A(2)(d) and as required under Schedule C, with whom they have shared the unpublished price sensitive information
