Is every sharing of information required to be recorded in the SEBI Structured Digital Database? What about downstream sharing?
All sharing must be recorded, including downstream sharing (sharing by people who have received the information). This is the reason that Affinis(SDD) has the most intuitive and easy-capture method that can additionally be captured in a single click for every additional sharing.
Affinis(SDD) can enable capture centrally or provide a distributed structure where each internal person, whether Insider or Designated Person or other internal person can capture the flow of their own UPSI. Affinis(SDD) also enables a mid-path that enables SPOCs to capture for each department.
Of course, downstream sharing by external persons is a part of their own compliance responsibilities.
