‘Unpublished price sensitive information’ (UPSI) means any information, relating to a company or its securities, directly or indirectly, that is not generally available which upon becoming generally available, is likely to materially affect the price of the securities and shall, ordinarily including but not restricted to, information relating to the following:
Key challenges faced by companies:
Technology has made access to data easier; it has opened multiple ways in which perpetrators can get access to a company’s UPSI. Based on KPMG in India’s experience of executing multiple data theft related investigations, captured below are a few key avenues which make companies prone to data theft.
Securing UPSI and ensuring that the data doesn’t fall in the wrong hands is critical for a company to ensure continued investor confidence, preserving its own reputation and goodwill in the market. Both these factors go a long way in ensuring smooth sailing for the company in these days of volatile markets and increased regulations and scrutiny.
It is imperative for companies to document the policy and process used to manage UPSI and ensure a comprehensive audit of the same from time to time. Red flags, if identified, from the audits should be documented and steps should be taken to mitigate the risks.
Increased awareness, automation and simplifying the whole process for insiders to comply is the key. In many cases, it is observed that ignorance leads to faults; hence the focus should be on educating and making employees and insiders aware of the law and the processes.
The insider threat - Safeguarding UPSI from within: A refresh
Unpublished Price Sensitive Information (UPSI) poses significant challenges for companies, requiring robust measures to prevent data theft and insider trading
Key Contacts
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