Insider-Trading (PIT) Code Administration

📘 Module 1: SEBI PIT Regulations – Legal Framework (1 Hour)

• Scope of SEBI (Prohibition of Insider Trading) Regulations, 2015
• Who qualifies as insiders, designated persons, connected persons
• Definition and handling of UPSI (Unpublished Price Sensitive Information)
• Penalties, enforcement actions and case precedents

📘 Module 2: Code of Conduct – Design, Content & Roles (1 Hour)

• Structure of the Code of Conduct under PIT rules
• Responsibilities of Compliance Officer and Designated Persons
• Institutionalizing internal control frameworks and escalation mechanisms
• Role of board and audit committee in oversight

📘 Module 3: Trading Windows, Pre-Clearance & Restricted Lists (1 Hour)

• Opening/closing of trading windows: timelines and logic
• Pre-clearance mechanism and holding periods
• Restricted lists and contra trade monitoring
• Audit trail, email triggers, and recordkeeping

📘 Module 4: Structured Digital Database (SDD) Management (1 Hour)

• Mandatory maintenance of SDD under amended regulations
• Fields, format, and technical configuration requirements
• Integration with ERP/email systems and time-stamping
• Internal audit checks and SDD testing procedures

📘 Module 5: Dealing with Violations & Reporting Protocols (1 Hour)

• Inquiry process and internal disciplinary actions
• SEBI reporting obligations (Reg. 9(1) and Reg. 9(2))
• Whistleblower and anonymous reporting systems
• Documentation of decisions and disciplinary actions

📘 Module 6: Live Simulation & Case Studies (45 Minutes)

• Real-world scenarios on UPSI leakage and breach detection
• Review of SEBI orders on insider trading lapses
• Mock audits and testing of PIT controls
• Checklist for compliance officers and company secretaries

🔒 Build a fortress of integrity — Equip your teams with operational command over insider trading compliance and PIT Code implementation.