Although not required by the FCA as part of SM&CR, it it nonetheless considered best practice to maintain a record of personal account dealings, (shares bought or sold), undertaken by Senior Managers within your firm. To do this:
Log into Corterum.
Click Workbench and then Datasets.
Click Staff, then Staff information.
A list of person entities will then be shown. Scroll to find the entity you are looking for and then click on their name.t.
Click Edit in the bottom-right corner of this pop-up to amend this entity's Staff Information dataset.
Scroll down until you see the Personal account dealing section.
If this is the first time you have recorded information about gifts and hospitality the button in this section will say Link Table. If you are adding to or amending an existing register - it will say View Table. Either way, click this button.
If you clicked Link table - you will. be presented with a pop up that asks you to Link to an existing dataset or to create a new one. Select New and then click CONFIRM.
NB - if you clicked View Table you will be. taken straight to the existing Personal account dealing record for the person entity you selected. Either. way, the instructions below can be used to edit or add to this register - you just need to click EDIT in the bottom-right corner of the gifts and hospitality register window.
You will then be taken to the Personal account dealing record, which is presented as a table dataset in a new pop-up window.
Firstly there's a dropdown box to identify who the list of is for. Select the correct person entity from the list.
Then you can use the fields underneath to record:
Date - the date that you're making this record.
Security - use this text box to record which security you are recording.
Symbol/stock code - use this text box to record the code or symbol of the security you are recording.
Number of shares - use this text box to record the amount of shares held by the Senior Manager.
Nature of transaction - use this free text box to record the nature of the transaction you are recording (e.g Purchase or Sale).
Nature of interest - use this text box to record the nature of the interest held in the stock (e.g. Direct or through intermediary).
Beneficial/Non-beneficial - record whether this transaction was beneficial to the Senior Manager or not in this text box.
If non-beneficial - use the Beneficial Owner text box to record the details of the beneficial owner.
Use the On/Off market dropdown box to record its on/off market status.
Broker - input the Broker name here.
Account number - Provide the Account number here.
Use the Approved? dropdown box to record whether the transaction was approved internally or not.
Then, use the Approved by dropdown to record the staff member within your firm that gave the approval.
Next, use the Approval date picker to record the date when approval was granted.
Then, use the free text box under Comments to provide any relevant context or commentary on the trade.
Finally, you can use the Documents section to upload any relevant supporting documentation by clicking the button.
If you need to create more entries. in the Register, click ADD ROW. Otherwise, click SAVE and then CLOSE.