1. Navigating to the Code of Ethics page

Click on the Code of Ethics menu of the left navigation panel. The following screenshot displays the Code of Ethics screen. The page lists the Time Trends, Pending Review and various Modules that are applicable.

Fig: 1 - Code of Ethics page

NOTE: If the user has navigated to this screen for the first time, the datasets of different sections can be blank.

2. Understanding the Various Elements of the Code of Ethics page

Refer to the following screenshot which is marked with numerical values that correspond to the below stated points.

Fig: 2 - Understanding the various elements of the Code of Ethics page

NOTE: The visibility of the datasets on the different sections of Code of Ethics and its reports are dependent on the role based access controls / permissions set for the user. For more details refer to the Roles online help.

The Time Trends visualization displays the count of the entries of the six modules of Code of Ethics in the form of horizontal bars which are color coded. By default, the current year is set. You can use the year selection dropdown at the top right to select another year, only if there is at least one entry created for that year. Changing the year selection loads the applicable count of module-wise entries for that year.

Fig: 3 - Color coded horizontal bar chart getting displayed

You can hover over any displayed bar chart to display a balloon tooltip denoting the module name and its count, beside the bar chart.

Fig: 4 - Balloon tooltip over horizontal bar chart getting displayed on mouse pointer hover

The Pending Review visualization displays the count of the pending entries of the six modules of Code of Ethics. The color coded pie chart denotes the percentage-wise distribution of the pending entries. If there is no pending entry, then that module-wise entry will be absent in the visible pie chart. Other applicable entries take up the pie chart area.

Fig: 5 - Color coded pie chart getting displayed

You can hover over this pie chart to display a balloon tooltip above it, denoting the module name and its count.

Fig: 6 - Color coded balloon tooltip over pie chart getting displayed on mouse pointer hover

Use the button to create a new rule applicable for any of three modules - Political Contributions, Outside Business Activities and Gifts & Entertainment.

Fig: 7 - + Add Rule button

More details have been mentioned in the respective Add New Rule sub-sections of this online help.

Click on the Past Code of Ethics Report button to navigate to the report of the Code of Ethics associated modules.

Fig: 8 - Past Code of Ethics Report button

Here is the view of the report page. More details have been mentioned in the respective report related sub-section of this online help.

Fig: 9 - Past Code of Ethics Report

Only the entries which are either having Status as Approved or Rejected will get displayed in the report. For more information, refer to this section.

The following six modules are present in this section:

1. Securities Trading
2. Gifts & Entertainment
3. Political Contributions
4. Outside Business Activities
5. Complaints
6. Outside Accounts

NOTE: All of the modules display Last reviewed, New Entries count and Latest Entry count.

Click on the View More button of any of the six modules to load its respective grid view.

Fig: 10 - Click on View More button of Securities Trading module to load the detailed view

3. Securities Trading

× A security is any financial instrument with a fungible value that investors can trade. Given the scope of the SurgeONE.ai application, securities include stocks only. In an effort to improve and update ethics compliance program, the Securities and Exchange Commission (SEC) periodically adopts changes to its rules. The rules, which regulate the securities holdings and transactions of all agency employees, their spouses, and their minor children, are updated by the SEC. Hence, you might need to setup defined rules and create trade related entries for your safekeeping or business compliance related purposes. Use this Securities Trading module to verify that all regulatory requirements and corporate policies are satisfied in employee trading and investing.

Securities Trading is the first module present in the grid view of the Code of Ethics page. There are two tabs present at the top labeled as Pre-Trade Approvals and Post-Trade. The following sub-sections explain in detail the associated functionalities.

3.1. Pre-Trade Approvals

This tab is selected by default. Existing pre-trade entries are listed out in the grid view. Click on the + Add Pre-Trades button to add a new entry. You can also search for existing entries using the search bar and filters. The following sub-sections illustrate these functionalities step-by-step.

3.1.1. Adding a new Pre-Trade > Adding Account Details

1. Click on the + Add Pre-Trades button to add a new entry.

Fig: 11 - + Add Pre-Trades button

The following screen loads. There are three tabs present as ADD ACCOUNT DETAILS, ADD PRE-TRADES and TRADES ATTESTATION.

Fig: 12 - ADD ACCOUNT DETAILS tab

2. Enter a suitable account name in the Account Name field.

Fig: 13 - Account Name field

3. Enter a suitable account number in the Account No. field.
4. Select a suitable account type in the Type of Account dropdown. The provided options are Brokerage, IRA, 401(k), Managed, 529, 403(b) and Equity.

Fig: 14 - Type of Account dropdown

5. Select a suitable account relation type in the Account Relation dropdown. The provided options are Personal, Spouse, Child, Family and Trustee.

Fig: 15 - Account Relation type dropdown

6. Click on the Add Account button to add the specified account details.

Fig: 16 - Add Account button

7. The specified account details get added. A new account details section load below it. You can edit the added account details if required.

Fig: 17 - Added new account details section

8. Perform the same steps as described above to provide multiple account details at one go. Click on the I don't have any accounts to add checkbox once your accounts are added. The Add Account button gets disabled after this checkbox selection.

Fig: 18 - Checkbox selection to proceed

9. Click on the Next button to proceed to the second stage.

Fig: 19 - Next button

NOTE:

• If you click on the Add Account button and data is not entered in the four mandatory fields, then the system will prompt appropriate validation tooltip below the concerned field.

Fig: 20 - Field validation tooltips

• Validation is employed on duplicate account numbers while adding the account details of pre-trade transactions.

Fig: 21 - Duplicate account number validation tooltip

3.1.2. Adding a new Pre-Trade > Adding Pre-Trades

Get redirected to the ADD PRE-TRADES tab to manually add pre trades. The following screen loads.

Fig: 22 - + Add Pre-Trades tab

1. Click on the Account No. dropdown to load its options. The account numbers that you added in the previous tab or you may have added earlier in sessions get listed here.

Fig: 23 - Added account numbers visible on expanded dropdown

Select a listed option of the Account No. dropdown.

2. Select a suitable security type from the Security Type dropdown list.

Fig: 24 - Security Type selection dropdown

3. Select a suitable security name from the Security Name dropdown list.

Fig: 25 - Security Name and Ticker field

After you select a stock, its corresponding ticker value gets auto-populated on the Ticker field. You cannot edit it.

4. Click on the Trade Date field to load the calendar. Select appropriate date to mark it as the date of trade. You cannot select a past date here since you are setting pre trade information.

Fig: 26 - Trade Date field date selection calendar

5. Select a suitable trade action type in the Trade Action dropdown. You can select either BUY or SELL.

Fig: 27 - Type of trade dropdown

6. Enter the traded quantity of the selected stocks in the Trade Quantity field. It should be a positive numeric value.
7. Enter the traded price per selected stock in the Trade Price field. It should be a positive numeric value.

Fig: 28 - Trade Quantity and Trade Price field

8. Click on the Add Trade button to add these details with all the details of the mandatory field denoted with asterisk(*) should be filled properly correct details.

Fig: 29 - Add Trade button

The specified account details get added in the grid view.

Fig: 30 - Added trades visible in grid view

9. Perform the same steps as described above to provide multiple pre-trade details at one go.
10. Click on the Next button to proceed to the last stage. You should have at least one trade added to proceed.

Fig: 31 - Next button

NOTE: If you click on the Add Account button and data is not entered in the mandatory fields, then the system will prompt appropriate validation tooltip below the concerned field.

Fig: 32 - Field validation tooltips

3.1.3. Adding a new Pre-Trade > Attesting Pre-Trades

Get redirected to the TRADES ATTESTATION tab to self-attest the added pre trades. The following screen loads.

Fig: 33 - TRADES ATTESTATION tab showing added pre-trade

1. Click on the checkbox labeled as I attest that this is a complete list of trades for the given time frame and this data is accurate to the best of my knowledge.

Fig: 34 - Attestation checkbox

2. After the checkbox selection, the Submit gets enabled. Click on it to submit the pre-trade entry.

Fig: 35 - Submit button

3. You get redirected to the Securities Trading page. The new pre-trade entry is visible in the grid view. The system displays a success notification at the top.

Fig: 36 - New pre-trade entry added in the grid view along with success notification

3.2. Post-Trade

This tab is next to the Pre-Trade tab. Existing post-trade entries are listed out in the grid view. Click on the + Add Post-Trades button to add a new entry. You can also search for existing entries using the search bar and filters. The following sub-sections illustrate these functionalities step-by-step.

3.2.1. Adding a new Post-Trade > Adding Account Details

1. Click on the + Add Post-Trades button to add a new entry.

Fig: 37 - + Add Post-Trades button

NOTE: Permitted user can also create post-trade entries by importing. It has been detailed here.

The following screen loads. There are three tabs present as ADD ACCOUNT DETAILS, ADD PRE-TRADES and TRADES ATTESTATION.

Fig: 38 - ADD ACCOUNT DETAILS tab

2. Enter a suitable account name in the Account Name field.

Fig: 39 - Account Name field

3. Enter a suitable account number in the Account No. field.
4. Select a suitable account type in the Type of Account dropdown. The provided options are Brokerage, IRA, 401(k), Managed, 529, 403(b) and Equity.

Fig: 40 - Type of Account dropdown

5. Select a suitable account relation type in the Account Relation dropdown. The provided options are Personal, Spouse, Child, Family and Trustee.

Fig: 41 - Type of Account dropdown

6. Click on the Add Account button to add the specified account details.

Fig: 42 - Add Account button

7. The specified account details get added. A new account details section load below it. You can edit the added account details if required.

Fig: 43 - Type of Account dropdown

8. Perform the same steps as described above to provide multiple account details at one go. Click on the I don't have any accounts to add checkbox once your accounts are added. The Add Account button gets disabled after this checkbox selection.

Fig: 44 - Type of Account dropdown

9. Click on the Next button at the bottom right, to proceed to the second stage.

NOTE:

• If you click on the Add Account button and data is not entered in the four mandatory fields, then the system will prompt appropriate validation tooltip below the concerned field.

Fig: 45 - Field validation tooltips

• Validation is employed on duplicate account numbers while adding the account details of pre-trade transactions.

Fig: 46 - Duplicate account number validation tooltip

3.2.2. Adding a new Post-Trade > Adding Post-Trades

Get redirected to the ADD POST-TRADES tab to manually add post trades. The following screen loads.

Fig: 47 - + Add Post-Trades button

1. Click on the Account No. dropdown to load its options. The account numbers that you added in the previous tab or you may have added earlier in sessions get listed here.

Fig: 48 - Added account numbers visible on expanded dropdown

Select a list option on the Account No. dropdown.

2. Select a suitable security type from the Security Type dropdown list and then select a suitable security name from the Security Name dropdown list.

After you select it, its corresponding ticker value gets auto-populated on the Ticker field. You cannot edit it.

Fig: 49 - Stock ticker value gets auto-populated

3. Click on the Trade Date field to load the calendar. Select appropriate date to mark it as the date of trade. You cannot select a future date here since you are setting post trade information.

Fig: 50 - Trade Date field

4. Select a suitable trade action type in the Trade Action dropdown. You can select either BUY or SELL.

Fig: 51 - Type of trade dropdown

5. Enter the traded quantity of the selected stocks in the Trade Quantity field. It should be a positive numeric value.
6. Enter the traded price per selected stock in the Trade Price field. It should be a positive numeric value.

Fig: 52 - Trade Quantity and Trade Price field

7. Click on the Add Trade button to add these details with all the details of the mandatory field denoted with asterisk(*) should be filled properly correct details.

Fig: 53 - Add Trade button

The specified account details get added in the grid view.

Fig: 54 - Added trades visible in grid view

8. Perform the same steps as described above to provide multiple pre-trade details at one go.
9. Click on the Next button to proceed to the last stage.

Fig: 55 - Next button

NOTE:

• If you click on the Add Account button and data is not entered in the mandatory fields, then the system will prompt appropriate validation tooltip below the concerned field.

Fig: 56 - Field validation tooltips

• You can click on the Upload Trades button to upload a .csv file instead of having to manually enter each trade details.

Fig: 57 - Upload Trades button

An Upload Trades dialog box loads for you to upload the filled-up template file. Click on the Continue button to upload the file, after browsing and selecting it.

Fig: 58 - Upload Trades dialog box

To obtain the template file, you can download it using the Download Template button of the Post-Trades tab. The following screenshot displays the format of the downloaded template file. The file name is COE_Account_Trade_Import_Template.

Fig: 59 - Downloading template

3.2.3. Adding a new Post-Trade > Attesting Post-Trades

Get redirected to the TRADES ATTESTATION tab to self-attest the added post trades. The following screen loads.

Fig: 60 - TRADES ATTESTATION tab showing added post-trade

1. Click on the checkbox labeled as I attest that this is a complete list of trades for the given time frame and this data is accurate to the best of my knowledge.
2. After the checkbox selection, the Submit gets enabled. Click on it to submit the post-trade entry.

Fig: 61 - Submit button

3. You get redirected to the Securities Trading page. The new post-trade entry is visible in the Post-Trades tab grid view. The system displays a success notification at the top.

Fig: 62 - New post-trade entry added in the grid view along with success notification

3.3. Securities Trading > Other Associated Functionalities

You can perform additional activities such as searching for added entries, approving a new entry, rejecting a new entry and viewing more information. Each of these activities have been briefly explained below.

1. Enter the name of any existing Securities Trading entry in the search bar.

Fig: 63 - Search bar

2. To further drill down search operation results, select an option of the Review Status dropdown. The following options are provided - All, Pending, Approved and Rejected.

Fig: 64 - Review Status dropdown options to set filter

3. You can also select an option of the Action dropdown. The following options are provided - BUY and SELL.

Fig: 65 - Action dropdown options to set filter

4. You can also select the starting date from the Start date calendar selection.

Fig: 66 - Start Date field to set filter

5. Similarly, the ending date can be set from the End date calendar selection.

Fig: 67 - End Date field to set filter

6. After setting the appropriate filters, you can click on the Apply Filter button.
7. Search results can be seen if matching entries are found.



Fig: 68 - Search results

You can click on the reset icon to remove the set filters.

A No matching records found label can be seen in the grid view, if no results are found from the search operation.



Fig: 69 - No search results found

NOTE: Search is executed based on the following parameters (displayed in the grid view as the column names).

• EMPLOYEE NAME
• DATE
• STOCK
• TICKER
• ACTION
• QUANTITY
• PRICE($)
• STATUS
• ACTION

All the columns are sortable, except for ACTION.

1. Click on the vertical ellipsis icon of the ACTION column to reveal the context menu options. Approve and Reject buttons are only available to users with appropriate permissions.
2. Click on the expanded Approve option.

Fig: 70 - Approve context menu option

NOTE: The REVIEW STATUS column must show the Pending label for an entry to be approved. A rejected entry cannot be approved.


3. A dialog box titled as Approve loads. Enter any applicable note in the Notes field, if required.

Fig: 71 - Approve dialog box

4. Upload a relevant attachment, if needed, using the Attachments - Click to upload file button.
5. Click on the Approve button.
6. You will get redirected to the listing page. The system will display a success notification at the top. The REVIEW STATUS value changes to Approved.

Fig: 72 - Approved success notification

NOTE: An email will get triggered to the user who created the trade entry in SurgeONE.ai, when the entry is approved.

Fig: 73 - Approved email triggered

1. Click on the vertical ellipsis icon of the ACTION column to reveal the context menu options. Approve and Reject buttons are only available to users with appropriate permissions.
2. Click on the expanded Reject option.


NOTE: The REVIEW STATUS column must show the Approved or Pending label for an entry to be rejected.


3. Enter any applicable note in the Notes field, if required.

Fig: 74 - Reject dialog box

4. Upload a relevant attachment, if needed, using the Attachments - Click to upload file button.
5. Click on the Reject button.

Fig: 75 - Reject button

6. In the listing page, the system displays a success notification at the top and the REVIEW STATUS value changes to Rejected.

Fig: 76 - Rejected success notification

NOTE: An email will get triggered to the user who created the trade entry in SurgeONE.ai, when the entry is rejected.

Fig: 77 - Rejected email triggered

1. Click on the vertical ellipsis icon of the ACTION column to reveal the context menu options.
2. Click on the expanded View More option.

Fig: 78 - View More context menu option

NOTE: The View More context menu is available for any listed entry.


3. A dialog box titled as PRE-TRADE DETAIL or POST-TRADE DETAIL loads (depending on the current tab selection). You can view the entry details as well as the approval / rejection notes and attachment filenames here.

Fig: 79 - Dialog box loads after clicking on View More context menu option

4. Gifts & Entertainment

× Gifts and entertainment policies are needed to be created to assist you in complying with all relevant regulations. Enterprises ought to follow protocols and guidelines that particularly tackle presents, tips, and amusement, along with the possible conflicts of interest that may arise during the operations. This module lets you set rules and make related entries for gifts & entertainment purposes. Rules can be incorporated to comply with regulations against bribery and corruption, and entries can be processed and managed swiftly.

Gifts & Entertainment is the second module present in the grid view of the Code of Ethics page. The following sub-sections explain in detail the associated functionalities.

Click on the View More option of the Gifts & Entertainment module.

Fig: 80 - View More option of the Gifts & Entertainment module

The following image shows the screen that loads.

Fig: 81 - Gifts & Entertainment module Recent Listings

4.1. Gifts & Entertainment > Create New Entry

1. Click on the + Add New Entry button of the Gifts & Entertainment listing screen.

Fig: 82 - Add New Entry button

The following image shows the screen that loads.









Fig: 83 - Gifts & Entertainment > Add New Entry

2. Click on the Date Sent On field to load the calendar. Select appropriate date the gift was sent on. You can make past or future-dated selection here.

Fig: 84 - Date Sent On field

3. Click on the Date Received On field to load the calendar. Select appropriate date the gift was received on. You can make past or future-dated selection here given that date received is greater than date sent on. This is an optional field.
4. Enter applicable price of the gift in the Amount($) field. It should be a positive integer greater than 0.

Fig: 85 - Amount($) field

5. Enter the name of the gift receiver in the Recipient Name field.

Fig: 86 - Recipient Name field

6. Click on the Recipient Type dropdown and select an appropriate option. The provided options are Client, Vendor and Employee respectively.

Fig: 87 - Recipient Type dropdown

7. Enter the name of the gift sender in the Received From field.

Fig: 88 - Received From field

8. Enter the account number of the client in the Client Account No. field. This field is enabled only when the Client option is selected in the Recipient Type dropdown.

Fig: 89 - Client Account No. field

9. Select the type of the listing in the Type field. Two options are provided as Gift and Entertainment.

Fig: 90 - Type dropdown

10. Enter the description in the Type Description field. This is an optional field.

Fig: 91 - Type Description field

11. Enter a note in the Notes field. This is an optional field.

Fig: 92 - Notes field

12. Click on the Add Entry button below it to store the entry as specified.









Fig: 93 - Add Entry button to add details

13. The new entry gets listed in the grid view. The above fields become blank. You can add more entries if you want. Perform the same steps as described above to provide multiple Gift and Entertainment entries details at one go.









Fig: 94 - Added new entry row

14. Select the I attest that this is a complete list of entries and this data is accurate to the best of my knowledge checkbox at the bottom. The Submit button gets enabled.



Fig: 95 - Added new entry row

15. Click on the Submit button add this new entry. You will get redirected to the Gifts & Entertainment Recent Listings page. The new entry is visible in the grid view. The system also displays a success notification at the top.



Fig: 96 - View of new entry added to recent listings and success notification

NOTE:

Validations employed

---

• If you click on the Add Entry button and have not entered data in all of the mandatory fields, then the system will prompt appropriate validation tooltip below the concerned field(s).

Fig: 97 - Field validation tooltips

• The date selection of the Date Received On field cannot be less than the date selection of the Date Sent On.

Fig: 98 - Date validation tooltip

• If the amount entered on the Amount($) field exceeds the defined transaction limit based on applied active rule, then the system will display validation tooltip below the field. You need to reduce it to be within the limit or increase the set limit to include it to proceed.

Fig: 99 - Amount exceeds active rule validation tooltip

• If the amount entered on the Amount($) field is less than one dollar, then the system will display validation tooltip below the field. You need to increase it above one dollar to proceed.

Fig: 100 - Amount low validation tooltip

• The entered value of the Amount($) field should be either an integer or a float value to proceed. If you enter a text value, then the system will prompt an appropriate validation tooltip below the field.

Fig: 101 - Amount($) field validation


Edit an entry

---

• If you add a new entry but are yet to submit it, and you click on the vertical ellipsis icon of the Action column, then a context menu loads. Click on the Edit option.

Fig: 102 - Edit context menu option

• The below screenshot has four numerical values indicated in it. The following points correlate with these values.
  1. The fields become populated with the entry details and are editable. You can modify any value.
  2. Two buttons labeled as Update Entry and Cancel can be seen below the fields. Click on the former to save any modifications made. Click on the latter to abort making any changes and leave the entry unedited.
  3. The context menu options are inactive during entry editing.
  4. The I attest that this is a complete list of entries and this data is accurate to the best of my knowledge checkbox becomes greyed out.

Fig: 103 - Various UI aspects while editing an entry


Delete an entry

---

• If you add a new entry but are yet to submit it, and you click on the vertical ellipsis icon of the Action column, then a context menu loads. Click on the Delete option.

Fig: 104 - Delete context menu option

• The entry gets removed.

Fig: 105 - Entry removed

4.2. Gifts & Entertainment > Add Rule

1. Click on the + Add Rule button of the Gifts & Entertainment listing screen.

Fig: 106 - Add Rule button

The following image shows the Add Rule screen that loads. There are three sections labeled as USD Limit Per Transaction, USD Limit Per Time Period and Frequency of Transaction Limit.











Fig: 107 - Adding rule for the Gifts & Entertainment module


1. USD Limit Per Transaction

---

2. Click on the Minimum Limit or Maximum Limit field under the For Gift header to enter the appropriate gift limit price. The amount entered here denotes the minimum or maximum permissible price of accepting a gift. If this price range is crossed while adding a gift entry, then system will block that addition and will prompt appropriate validation to the user.

Fig: 108 - USD limit per transaction for a gift entry as Minimum and Maximum Limit

3. Click on the Minimum Limit or Maximum Limit field under the For Entertainment header to enter the appropriate gift limit price. The amount entered here denotes the minimum or maximum permissible price of accepting a gift. If this price range is crossed while adding an entertainment entry, then system will block that addition and will prompt appropriate validation to the user.

Fig: 109 - USD limit per transaction for an entertainment entry


2. USD Limit Per Time Period

---

4. Click on the Time Period dropdown under the For Gift label to select the applicable time period for which the rule is being added. There are three selectable options as Monthly, Quarterly and Annually.

Fig: 110 - Time Period dropdown under the For Gift label

5. Under the For Gift label, enter the gift limit price in the USD Limit field. The amount entered here denotes the maximum permissible total price of accepting a gift for the selected time period. If this total price is exceeded for the time period while adding a gift entry, then system will block that addition and will prompt appropriate validation to the user.

Fig: 111 - USD Limit field under the For Gift label

6. Click on the Time Period dropdown under the For Entertainment label to select the applicable time period for which the rule is being added. There are three selectable options as Monthly, Quarterly and Annually.



Fig: 112 - Time Period dropdown under the For Entertainment label

7. Under the For Entertainment label, enter the gift limit price in the USD Limit field. The amount entered here denotes the maximum permissible total price of accepting any entertainment for the selected time period. If this total price is exceeded for the time period while adding an entertainment entry, then system will block that addition and will prompt appropriate validation to the user.

Fig: 113 - USD Limit field under the For Entertainment label


3. Frequency of Transaction Limit

---

8. Click on the Frequency dropdown under the For Gift label to select the applicable frequency for which the rule is being added. There are three selectable options as Monthly, Quarterly and Annually.

Fig: 114 - Frequency dropdown under the For Gift label

9. Under the For Gift label, enter the gift limit price in the No. of Transactions field. The amount entered here denotes the maximum permissible transaction count of accepting a gift for the selected time period. If this total count of transactions is exceeded for the time period while adding a gift entry, then system will block that addition and will prompt appropriate validation to the user.

Fig: 115 - No. of Transactions field under the For Gift label

10. Click on the Frequency dropdown under the For Entertainment label to select the applicable frequency for which the rule is being added. There are three selectable options as Monthly, Quarterly and Annually.

Fig: 116 - Frequency dropdown under the For Entertainment label

11. Under the For Entertainment label, enter the entertainment limit price in the No. of Transactions field. The amount entered here denotes the maximum permissible transaction count of accepting any entertainment for the selected time period. If this total count of transactions is exceeded for the time period while adding an entertainment entry, then system will block that addition and will prompt appropriate validation to the user.



Fig: 117 - No. of Transactions field under the For Entertainment label

12. Click on the Submit button below it. The new rule(s) gets added.

NOTE:

• You can add a rule in one field or in multiple fields of the Add Rule screen.
• You add click on the + Add Rule button to view the submitted rules.

Fig: 118 - Added Gifts & Entertainment rules visible

4.3. Gifts & Entertainment > Other Associated Functionalities

You can perform additional activities such as searching for added entries, approving a new entry, rejecting a new entry and viewing more information. Each of these activities have been briefly explained below.

1. Enter the name of any existing Gifts & Entertainment entry in the search bar.

Fig: 119 - Search bar

2. To further drill down search operation results, select an option of the Review Status dropdown. The following options are provided - All, Pending, Approved and Rejected.

Fig: 120 - Review Status dropdown options to set filter

3. Search results can be seen if matching entries are found.

Fig: 121 - Search results

A No matching records found label can be seen in the grid view, if no results are found from the search operation.

Fig: 122 - No search results found

NOTE: Search is executed based on the following parameters (displayed in the grid view as the column names).

• EMPLOYEE NAME
• DATE SENT
• RECIPIENT NAME
• RECIPIENT TYPE
• RECEIVED FROM
• TYPE DESCRIPTION
• AMOUNT($)
• REVIEW STATUS
• ACTION

All the columns are sortable, except for ACTION.

1. Click on the vertical ellipsis icon of the ACTION column to reveal the context menu options. Approve and Reject buttons are only available to people with appropriate permissions.
2. Click on the expanded Approve option.

Fig: 123 - Approve context menu option

NOTE: The REVIEW STATUS column must show the Pending label for an entry to be approved. A rejected entry cannot be approved.


3. A dialog box titled as Approve loads. Enter any applicable note in the Notes field, if required.

Fig: 124 - Approve dialog box

4. Upload a relevant attachment, if needed, using the Attachments - Click to upload file button.
5. Click on the Approve button.

Fig: 125 - Approve button

6. You will get redirected to the listing page. The system will display a success notification at the top. The REVIEW STATUS value changes to Approved.

Fig: 126 - Approved success notification

NOTE: An email will get triggered to the user who created the Gifts & Entertainment entry in SurgeONE.ai, when the entry is approved.

Fig: 127 - Approved email triggered

1. Click on the vertical ellipsis icon of the ACTION column to reveal the context menu options. Approve and Reject buttons are only available to people with appropriate permissions.
2. Click on the expanded Reject option.

Fig: 128 - Reject context menu option

NOTE: The REVIEW STATUS column must show the Approved or Pending label for an entry to be rejected.


3. A dialog box titled as Reject loads. Enter any applicable note in the Notes field, if required.

Fig: 129 - Reject dialog box

4. Upload a relevant attachment, if needed, using the Attachments - Click to upload file button.

Fig: 130 - Attachment upload button

5. Click on the Reject button.

Fig: 131 - Reject button

6. You will get redirected to the listing page. The system will display a success notification at the top. The REVIEW STATUS value changes to Rejected.

Fig: 132 - Rejected success notification

NOTE: An email will get triggered to the user who created the Gifts & Entertainment entry in SurgeONE.ai, when the entry is rejected.

Fig: 133 - Rejected email triggered

1. Click on the vertical ellipsis icon of the ACTION column to reveal the context menu options.
2. Click on the expanded View More option.

Fig: 134 - View More context menu option

NOTE: The View More context menu is available for any listed entry.


3. A dialog box titled as GIFTS & ENTERTAINMENT loads. You can view the entry details as well as the approval / rejection notes and attachment filenames here.

Fig: 135 - Dialog box loads after clicking on View More context menu option

5. Political Contributions

× Election campaigns bring in large sums of money for political causes every few years, making it difficult for compliance teams to continue being productive. Contributions to multiple entities and groups make handling conflicts of interest and compliance challenges more difficult. Investment advisors and corporates may face compliance issues and reputational hazards as a result of political contributions. Keep track of the names of people or political organizations that have benefited from any donations given by staff members or your organization. This module lets you set rules and make related entries for any political contribution purposes, to establish guidelines for data checking upon submission, thereby mitigating the likelihood of conflicts slipping through the cracks.

It is the third module present in the grid view of the Code of Ethics page. The following sub-sections explain in detail the associated functionalities.

Click on the View More option of the Political Contributions module.

Fig: 136 - View More option of the Political Contributions module

The following image shows the screen that loads.

Fig: 137 - Political Contributions module Recent Listings

5.1. Political Contributions > Create New Entry

1. Click on the + Add New Entry button of the Political Contributions listing screen.

Fig: 138 - Add New Entry button

The following image shows the screen that loads.









Fig: 139 - Political Contributions > Add New Entry

2. Click on the Date Given On field to load the calendar. Select appropriate date the political contribution was made or is to be made. You can make past or future-dated selection here.

Fig: 140 - Date Given On field

3. Enter the name of the donor who is making this political contribution in the Donor Name field.

Fig: 141 - Donor Name field

4. Select the relationship of the donor with the employee who is making this entry. From the Employee Relation dropdown you can select either of the following options - Self, Spouse, Child, Family, Trustee and Others.

Fig: 142 - Employee Relation dropdown

5. Enter the name of the receiver who is going to get this political contribution in the Donated To field.

Fig: 143 - Donated To field

6. Enter the current designation or the position held by the contribution receiver in the Political Position field.

Fig: 144 - Political Position field

7. Enter the contributed amount in the Amount($) field. It should be a positive numeric value.

Fig: 145 - Amount($) field

8. Select the state name from the State dropdown. Currently, the states of USA are listed here.

Fig: 146 - State dropdown

9. Select the city name from the City dropdown. The dropdown is enabled after state selection and is populated with the cities of the selected state.

Fig: 147 - City dropdown

10. Enter a note in the Notes field. This is an optional field.

Fig: 148 - Notes field

11. Click on the Add Entry button below it to store the entry as specified.









Fig: 149 - Add Entry button to add details

12. The new entry gets listed in the grid view. The above fields become blank. You can add more entries if you want.









Fig: 150 - Added new entry row

13. Select the I attest that this is a complete list of entries and this data is accurate to the best of my knowledge checkbox at the bottom. The Submit button gets enabled.



Fig: 151 - Added new entry row

14. Click on the Submit button add this new entry. You will get redirected to the Political Contributions Recent Listings page. The new entry is visible in the grid view. The system also displays a success notification at the top.



Fig: 152 - View of new entry added to recent listings and success notification

NOTE:

Validations employed

---

• If you click on the Add Entry button and have not entered data in all of the mandatory fields, then the system will prompt appropriate validation tooltip below the concerned field(s).

Fig: 153 - Field validation tooltips

• If the amount entered on the Amount($) field exceeds the defined transaction limit based on applied active rule, then the system will display validation tooltip below the field. You need to reduce it to be within the limit or increase the set limit to include it to proceed.

Fig: 154 - Amount exceeds active rule validation tooltip

• If there is no defined transaction limit or no active rule is set, then the system will prompt a confirmation dialog box. You need to click on the Yes button to proceed.

Fig: 155 - Confirmation prompt to proceed

• If the amount entered on the Amount($) field is less than one dollar, then the system will display validation tooltip below the field. You need to increase it above one dollar to proceed.

Fig: 156 - Amount low validation tooltip

• If the amount entered on the Amount($) field is a text (instead of an integer or float), then the system will display validation tooltip below the field. You need to remove it and insert valid numeric value to proceed.

Fig: 157 - Amount field text validation tooltip


Edit an entry

---

• If you add a new entry but are yet to submit it, and you click on the vertical ellipsis icon of the Action column, then a context menu loads. Click on the Edit option.

Fig: 158 - Edit context menu option

• The below screenshot has four numerical values indicated in it. The following points correlate with these values.
  • The fields become populated with the entry details and are editable. You can modify any value.
  • Two buttons labeled as Update Entry and Cancel can be seen below the fields. Click on the former to save any modifications made. Click on the latter to abort making any changes and leave the entry unedited.
  • The context menu options are inactive during entry editing.
  • The I attest that this is a complete list of entries and this data is accurate to the best of my knowledge checkbox becomes greyed out.

Fig: 159 - Various UI aspects while editing an entry


Delete an entry

---

• If you add a new entry but are yet to submit it, and you click on the vertical ellipsis icon of the Action column, then a context menu loads. Click on the Delete option.

Fig: 160 - Delete context menu option

• The entry gets removed.

5.2. Political Contributions > Add Rule

1. Click on the + Add Rule button of the Political Contributions listing screen.

Fig: 161 - Add Rule button

The following image shows the Add Rule screen that loads. There are two sections labeled as USD Limit Per Transaction and USD Limit Per Time Period.











Fig: 162 - Adding rule for the Political Contributions module


1. USD Limit Per Transaction

---

2. Enter the limit of political contribution in USD in the USD Limit Per Transaction field. The amount entered here denotes the maximum permissible price of accepting a contribution in the system. If this price is exceeded while adding a political contribution entry, then system will block that addition and will prompt appropriate validation to the user.

Fig: 163 - USD limit per transaction for a political contribution entry


2. USD Limit Per Time Period

---

3. Click on the Time Period dropdown under the USD Limit Per Time Period label to select the applicable time period for which the rule is being added. There are three selectable options as Monthly, Quarterly and Annually.

Fig: 164 - Time Period dropdown under the USD Limit Per Time Period label

4. Enter the political contribution limit price in the USD Limit field. The amount entered here denotes the maximum permissible total price of accepting a political contribution for the selected time period. If this total price is exceeded for the time period while adding a political contribution entry, then system will block that addition and will prompt appropriate validation to the user.

Fig: 165 - USD Limit field under the USD Limit Per Time Period label

5. Click on the Submit button below it. The new rule(s) gets added.

NOTE:

• You can add a rule in one field or in multiple fields of the Add Rule screen.
• You add click on the + Add Rule button to view the submitted rules.

Fig: 166 - Added Political Contribution rules visible

5.3. Political Contributions > Other Associated Functionalities

You can perform additional activities such as searching for added entries, approving a new entry, rejecting a new entry and viewing more information. Each of these activities have been briefly explained below.

1. Enter the name of any existing Political Contributions entry in the search bar.

Fig: 167 - Search bar

2. To further drill down search operation results, select an option of the Review Status dropdown. The following options are provided - All, Pending, Approved and Rejected.

Fig: 168 - Review Status dropdown options to set filter

3. Search results can be seen if matching entries are found.

Fig: 169 - Search results

A No matching records found label can be seen in the grid view, if no results are found from the search operation.

NOTE: Search is executed based on the following parameters (displayed in the grid view as the column names).

• EMPLOYEE NAME
• DATE GIVEN
• DONOR
• EMPLOYEE RELATION
• DONATED TO
• POLITICAL POSITION
• AMOUNT($)
• REVIEW STATUS
• ACTION

All the columns except for ACTION are sortable.

1. Click on the vertical ellipsis icon of the ACTION column to reveal the context menu options. Approve and Reject buttons are only available to people with appropriate permissions.
2. Click on the expanded Approve option.

Fig: 170 - Approve context menu option

NOTE: The REVIEW STATUS column must show the Pending label for an entry to be approved. A rejected entry cannot be approved.


3. A dialog box titled as Approve loads. Enter any applicable note in the Notes field, if required.

Fig: 171 - Approve dialog box

4. Upload a relevant attachment, if needed, using the Attachments - Click to upload file button.
5. Click on the Approve button.

Fig: 172 - Approve button

6. You will get redirected to the listing page. The system will display a success notification at the top. The REVIEW STATUS value changes to Approved.

Fig: 173 - Approved success notification

NOTE: An email will get triggered to the user who created the Political Contributions entry in SurgeONE.ai, when the entry is approved.

Fig: 174 - Approved email triggered

1. Click on the vertical ellipsis icon of the ACTION column to reveal the context menu options. Approve and Reject buttons are only available to people with appropriate permissions.
2. Click on the expanded Reject option.

Fig: 175 - Reject context menu option

NOTE: The REVIEW STATUS column must show the Approved or Pending label for an entry to be rejected.


3. A dialog box titled as Reject loads. Enter any applicable note in the Notes field, if required.

Fig: 176 - Reject dialog box

4. Upload a relevant attachment, if needed, using the Attachments - Click to upload file button.

Fig: 177 - Attachment upload button

5. Click on the Reject button.

Fig: 178 - Reject button

6. You will get redirected to the listing page. The system will display a success notification at the top. The REVIEW STATUS value changes to Rejected.

Fig: 179 - Rejected success notification

NOTE: An email will get triggered to the user who created the Political Contributions entry in SurgeONE.ai, when the entry is rejected.

Fig: 180 - Rejected email triggered

1. Click on the vertical ellipsis icon of the ACTION column to reveal the context menu options.
2. Click on the expanded View More option.

Fig: 181 - View More context menu option

NOTE: The View More context menu is available for any listed entry.


3. A dialog box titled as Political Contributions loads. You can view the entry details as well as the approval / rejection notes and attachment filenames here.

Fig: 182 - Dialog box loads after clicking on View More context menu option

6. Outside Business Activities

× Conflicts of interest may arise between individuals and the registered investment advisers who hire them as a result of their Outside Business Activities (OBAs). Any business or activity that a registered representative engages in that is not related to their member firm falls under the purview of an OBA. Financial advisors are required to give written notice to their member companies prior to conducting any business outside of the firm. The power to accept or reject proposed OBAs is held by member firms. The protection of the company and its client interests depends heavily on this. This module lets you set rules and make related entries to keep track of outside business activities. Prevent employees external business activities from causing regulatory compliance violations. It is simple to keep track of the connected individuals, family members, and employees' related activities, as well as donations to charities.

It is the fourth module present in the grid view of the Code of Ethics page. The following sub-sections explain in detail the associated functionalities.

Click on the View More option of the Outside Business Activities module.

Fig: 183 - View More option of the Outside Business Activities module

The following image shows the screen that loads.

Fig: 184 - Outside Business Activities module Recent Listings

6.1. Outside Business Activities > Create New Entry

1. Click on the + Add New Entry button of the Outside Business Activities listing screen.

Fig: 185 - Add New Entry button

The following image shows the screen that loads.









Fig: 186 - Outside Business Activities > Add New Entry

2. Click on the Start Date field to load the calendar. Select appropriate start date the outside business activity began or is to be started. You can make past or future-dated selection here.

Fig: 187 - Start Date calendar selection

3. Click on the End Date field to load the calendar. Select appropriate end date the outside business activity was finished on. You can make past or future-dated selection here. However, the end date must be later than the start date.

Fig: 188 - End Date calendar selection

4. Enter the name of the participant of this outside business activity in the Participant field.

Fig: 189 - Participant field

5. Select the relationship of the participant with the employee who is making this entry. From the Employee Relation dropdown you can select either of the following options - Self, Spouse, Child, Family, Trustee and Others.

Fig: 190 - Employee Relation dropdown

6. Enter the name of the concerned business in the Outside Business Name(OBA) field.

Fig: 191 - Outside Business Name(OBA) field

7. Enter a suitable description of this in the OBA Description field.

Fig: 192 - OBA Description field

8. Enter the current position or affiliation or the relationship with this outside business in the Position/Title/Relation with Outside Business field. It is an optional field.

Fig: 193 - Position/Title/Relation with Outside Business field

9. Enter the address of this outside business in the Address of Outside Business field. It is an optional field.

Fig: 194 - Address of Outside Business field

10. Enter the type of this outside business or the service(s) offered by it in the Nature of Outside Business field. It is an optional field.

Fig: 195 - Nature of Outside Business field

11. Specify whether the organization is involved in investment-related activities or projects. It is an optional field. To select, enable the Is Business Investment Related? slider.

Fig: 196 - Is Business Investment Related? slider

12. Enter the duration of the total time (Hrs Per Month) spent in this outside business in the Time Devoted in Outside Business (Hrs Per Month) field.

Fig: 197 - Time Devoted in Outside Business (Hrs Per Month) field

13. Enter the duration of the total time (Hrs Per Month) spent outside business during trading hours in the Time Devoted in Outside Business During Trading (Hrs Per Month) field. It is an optional field.

Fig: 198 - Time Devoted in Outside Business (Hrs Per Month) field

14. Enter a note in the Notes field. This is an optional field.

Fig: 199 - Notes field

15. Click on the Add Entry button below it to store the entry as specified.









Fig: 200 - Add Entry button to add details

16. The new entry gets listed in the grid view. The above fields become blank. You can add more entries if you want.









Fig: 201 - Added new entry row

17. Select the I attest that this is a complete list of entries and this data is accurate to the best of my knowledge checkbox at the bottom. The Submit button gets enabled.



Fig: 202 - Added new entry row

18. Click on the Submit button add this new entry. You will get redirected to the Outside Business Activities Recent Listings page. The new entry is visible in the grid view. The REVIEW STATUS column displays the PENDING status. The system also displays a success notification at the top.



Fig: 203 - View of new entry added to recent listings and success notification

NOTE:

Validations employed

---

• If you click on the Add Entry button and have not entered data in all of the mandatory fields, then the system will prompt appropriate validation tooltip below the concerned field(s).

Fig: 204 - Field validation tooltips

• The date selection of the End Date field cannot be less than the date selection of the Start Date. It must be a later date or the same date.

Fig: 205 - Date validation tooltip

• The durations entered in the Time Devoted in Outside Business (Hrs Per Month) field and the Time Devoted in Outside Business During Trading (Hrs Per Month) field must be integers and not float values or text.

Fig: 206 - Duration validation tooltip


Edit an entry

---

• If you add a new entry but are yet to submit it, and you click on the vertical ellipsis icon of the Action column, then a context menu loads. Click on the Edit option.

Fig: 207 - Edit context menu option

• The below screenshot has four numerical values indicated in it. The following points correlate with these values.
  1. The fields become populated with the entry details and are editable. You can modify any value.
  2. Two buttons labeled as Update Entry and Cancel can be found below the fields. Click on the former to save any modifications made. Click on the latter to abort making any changes and leave the entry unedited.
  3. The context menu options are inactive during entry editing.
  4. The I attest that this is a complete list of entries and this data is accurate to the best of my knowledge checkbox becomes greyed out.

Fig: 208 - Various UI aspects while editing an entry


Delete an entry

---

• If you add a new entry but are yet to submit it, and you click on the vertical ellipsis icon of the Action column, then a context menu loads. Click on the Delete option.

Fig: 209 - Delete context menu option

• The entry gets removed.

6.2. Outside Business Activities > Add Rule

1. Click on the + Add Rule button of the Outside Business Activities listing screen.

Fig: 210 - Add Rule button

The following image shows the Add Rule screen that loads. There is a section labeled as Prohibited Activities.









Fig: 211 - Adding rule for the Outside Business Activities module

2. Enter the applicable prohibited activity in the Prohibited Activities field with the placeholder label Enter Prohibited Activities.

Fig: 212 - Field to state a prohibited activity

3. Click on the Add button beside it.

Fig: 213 - Add button to define a prohibited activity

4. The new rule(s) gets added to the right. You can view the added rule. If it is long, then the text is displayed as truncated. If required, click on the cross icon to remove it.

Fig: 214 - Stated rule visible

You can click on the View More button to view it. After viewing the added rule in the Prohibited Activities dialog box, click on the Close button to exit this view.

Fig: 215 - View More dialog box

5. Click on the Submit button below it.

Fig: 216 - Rule Submit button

The new rule(s) gets added. You will get redirected to the Outside Business Activities Recent Listings page.

NOTE:

• You add add multiple rules at one go. Here is the view of two rules added.

Fig: 217 - Two added rules visible

• You add click on the + Add Rule button to view the submitted rules.

Fig: 218 - Added Outside Business Activities rules visible

• If you click on the Add button without entering any text in the field to state a new prohibited activity, the system will prompt validation tooltip below it.

Fig: 219 - Validation tooltip to enter text

• If you click on the Add button after entering any text in the field to state a new prohibited activity, and the entered text matches with any existing Outside Business Activity (OBA) rule, then the system will prompt validation tooltip below it.

Fig: 220 - Validation tooltip on duplicate rule

6.3. Outside Business Activities > Other Associated Functionalities

You can perform additional activities such as searching for added entries, approving a new entry, rejecting a new entry and viewing more information. Each of these activities have been briefly explained below.

1. Enter the name of any existing Outside Business Activities entry in the search bar.

Fig: 221 - Search bar

2. To further drill down search operation results, select an option of the Review Status dropdown. The following options are provided - All, Pending, Approved and Rejected.

Fig: 222 - Review Status dropdown options

3. Search results can be seen if matching entries are found.

Fig: 223 - Search results

A No matching records found label can be seen in the grid view, if no results are found from the search operation.

Fig: 224 - No search results found

NOTE: Search is executed based on the following parameters (displayed in the grid view as the column names).

• EMPLOYEE NAME
• START DATE
• PARTICIPANT
• EMPLOYEE RELATION
• OUTSIDE BUSINESS NAME (OBA)
• OBA DESCRIPTION
• TIME DEVOTED
• REVIEW STATUS
• ACTION

All the columns are sortable, except for ACTION.

1. Click on the vertical ellipsis icon of the ACTION column to reveal the context menu options. Approve and Reject buttons are only available to people with appropriate permissions.
2. Click on the expanded Approve option.

Fig: 225 - Approve context menu option

NOTE: The REVIEW STATUS column must show the Pending label for an entry to be approved. A rejected entry cannot be approved.


3. A dialog box titled as Approve loads. Enter any applicable note in the Notes field, if required.

Fig: 226 - Approve dialog box

4. Upload a relevant attachment, if needed, using the Attachments - Click to upload file button.
5. Click on the Approve button.

Fig: 227 - Approve button

6. You will get redirected to the listing page. The system will display a success notification at the top. The REVIEW STATUS value changes to Approved.

Fig: 228 - Approved success notification

NOTE: An email will get triggered to the user who created the Outside Business Activities entry in SurgeONE.ai, when the entry is approved.

Fig: 229 - Approved email triggered

1. Click on the vertical ellipsis icon of the ACTION column to reveal the context menu options. Approve and Reject buttons are only available to people with appropriate permissions.
2. Click on the expanded Reject option.

Fig: 230 - Reject context menu option

NOTE: The REVIEW STATUS column must show the Approved or Pending label for an entry to be rejected.


3. A dialog box titled as Reject loads. Enter any applicable note in the Notes field, if required.

Fig: 231 - Reject dialog box

4. Upload a relevant attachment, if needed, using the Attachments - Click to upload file button.

Fig: 232 - Attachment upload button

5. Click on the Reject button.

Fig: 233 - Reject button

6. You will get redirected to the listing page. The system will display a success notification at the top. The REVIEW STATUS value changes to Rejected.

Fig: 234 - Rejected success notification

NOTE: An email will get triggered to the user who created the Outside Business Activities entry in SurgeONE.ai, when the entry is rejected.

Fig: 235 - Rejected email triggered

1. Click on the vertical ellipsis icon of the ACTION column to reveal the context menu options.
2. Click on the expanded View More option.

Fig: 236 - View More context menu option

NOTE: The View More context menu is available for any listed entry.


3. A dialog box titled as Outside Business Activities loads. You can view the entry details as well as the approval / rejection notes and attachment filenames here.

Fig: 237 - Dialog box loads after clicking on View More context menu option

7. Complaints

× Users can report possible securities law violations like insider trading, cryptocurrency, manipulation of securities/prices, advance fee fraud, account administration and processing, transfer of account, theft/forgery, short selling, delivery of funds/proceeds, high-yield investment schemes, etc.

It is the fifth module present in the grid view of the Code of Ethics page. The following sub-sections explain in detail the associated functionalities.

Click on the View More option of the Complaints module.

Fig: 238 - View More option of the Complaints module

The following image shows the screen that loads.

Fig: 239 - Complaints module Recent Listings

7.1. Complaints > Create New Entry

1. Click on the + Add New Entry button of the Complaints listing screen.

Fig: 240 - Add New Entry button

The following image shows the screen that loads.









Fig: 241 - Complaints > Add New Entry

2. Click on the Date Received field to load the calendar. Select appropriate start date the complaint is received or is to be lodged on. You can make past or current-dated selection here.

Fig: 242 - Date Received calendar selection

3. Enter the name of the client who reported the complaint in the Client Name field. It is an optional field.

Fig: 243 - Client Name field

4. Enter the account number of the client who reported the complaint in the Account Number field.

Fig: 244 - Account Number field

5. Select the type of the reported complaint in the Complaint Type dropdown. The provided options are Email, Phone Call, In Person and Self.

Fig: 245 - Complaint Type dropdown

6. Select the type of the violation in the Violation dropdown. The provided options are Excessive Trading, Forgery, Poor Customer Service, Unauthorized Transactions, Stolen Securities/Funds, Transfer of account problem, Unsuitable recommendations, Business Owner and Employment.

Fig: 246 - Violation dropdown

7. Enter the disputed amount in dollars in the Dispute Amount ($) field. It should be a positive numeric value.

Fig: 247 - Dispute Amount ($) field

8. Select the type of security related with the complaint in the Security Type dropdown. The provided options are Stock, Equity, Debt, Derivative, Hybrid and Other - Manual Entry. It is an optional field.

Fig: 248 - Security Type dropdown

9. Select the security name from the Security Name dropdown options. After you select it, the ticker value corresponding to the security gets populated in the Ticker field.

Fig: 249 - Security Symbol dropdown

10. Enter the name of the involved security in the Security Name field. It is an optional field.

Fig: 250 - Security Name field"/span>

11. Specify whether the client has already reported to the SEC or FINRA. If the answer is yes, then enable the Has the client filed a complaint with the SEC or FINRA? slider. It is an optional field.

Fig: 251 - Has the client filed a complaint with the SEC or FINRA? slider

12. Select the date of issue/dispute occurence in the Date of Event field.

Fig: 252 - Date of Event field

13. Click on the Add Entry button below it to store the entry as specified.









Fig: 253 - Add Entry button to add details

14. The new entry gets listed in the grid view. The above fields become blank. You can add more entries if you want.









Fig: 254 - Added new entry row

15. Select the I attest that this is a complete list of entries and this data is accurate to the best of my knowledge checkbox at the bottom. The Submit button gets enabled.



Fig: 255 - Added new entry row

16. Click on the Submit button add this new entry. You will get redirected to the Complaints Recent Listings page. The new entry is visible in the grid view. The REVIEW STATUS column displays the PENDING status. The system also displays a success notification at the top.



Fig: 256 - View of new entry added to recent listings and success notification

NOTE:

Validations employed

---

• If you click on the Add Entry button and have not entered data in all of the mandatory fields, then the system will prompt appropriate validation tooltip below the concerned field(s).

Fig: 257 - Field validation tooltips

• The date selection of the Date Received calendar cannot be a future-dated selection.

Fig: 258 - Date Received calendar constraint

• The date selection of the Date of Event field should be less or equal to the Date Received field value.

Fig: 259 - Date of Event field validation

• The entered value of the Dispute Amount ($) field should be either an integer or a float value to proceed. If you enter a text value, then the system will prompt an appropriate validation tooltip below the field.

Fig: 260 - Dispute Amount ($) field validation


Edit an entry

---

• If you add a new entry but are yet to submit it, and you click on the vertical ellipsis icon of the Action column, then a context menu loads. Click on the Edit option.

Fig: 261 - Edit context menu option

• The below screenshot has four numerical values indicated in it. The following points correlate with these values.
  1. The fields become populated with the entry details and are editable. You can modify any value.
  2. Two buttons labeled as Update Entry and Cancel load below the fields. Click on the former to save any modifications made. Click on the latter to abort making any changes and leave the entry unedited.
  3. The context menu options are inactive during entry editing.
  4. The I attest that this is a complete list of entries and this data is accurate to the best of my knowledge checkbox becomes greyed out.

Fig: 262 - Various UI aspects while editing an entry


Delete an entry

---

• If you add a new entry but are yet to submit it, and you click on the vertical ellipsis icon of the Action column, then a context menu loads. Click on the Delete option.

Fig: 263 - Delete context menu option

• The entry gets removed.

7.2. Complaints > Other Associated Functionalities

You can perform additional activities such as searching for added entries, approving a new entry, rejecting a new entry and viewing more information. Each of these activities have been briefly explained below.

1. Enter the name of any existing Complaints entry in the search bar.

Fig: 264 - Search bar

2. To further drill down search operation results, select an option of the Review Status dropdown. The following options are provided - All, Pending, Approved and Rejected.

Fig: 265 - Review Status dropdown options

3. Search results can be seen if matching entries are found.

Fig: 266 - Search results

A No matching records found label can be seen in the grid view, if no results are found from the search operation.

Fig: 267 - No search results found

NOTE: Search is executed based on the following parameters (displayed in the grid view as the column names).

• EMPLOYEE NAME
• DATE RECEIVED
• CLIENT NAME
• COMPLAINT TYPE
• VIOLATION
• DISPUTE AMOUNT($)
• REVIEW STATUS
• ACTION

All the columns except for ACTION are sortable.

1. Click on the vertical ellipsis icon of the ACTION column to reveal the context menu options. Approve and Reject buttons are only available to people with appropriate permissions.
2. Click on the expanded Approve option.

Fig: 268 - Approve context menu option

NOTE: The REVIEW STATUS column must show the Pending label for an entry to be approved. A rejected entry cannot be approved.


3. A dialog box titled as Approve loads. Enter any applicable note in the Notes field, if required.

Fig: 269 - Approve dialog box

4. Upload a relevant attachment, if needed, using the Attachments - Click to upload file button.
5. Click on the Approve button.

Fig: 270 - Approve button

6. You will get redirected to the listing page. The system will display a success notification at the top. The REVIEW STATUS value changes to Approved.

Fig: 271 - Approved success notification

NOTE: An email will get triggered to the user who created the Complaints entry in SurgeONE.ai, when the entry is approved.

Fig: 272 - Approved email triggered

1. Click on the vertical ellipsis icon of the ACTION column to reveal the context menu options. Approve and Reject buttons are only available to people with appropriate permissions.
2. Click on the expanded Reject option.

Fig: 273 - Reject context menu option

NOTE: The REVIEW STATUS column must show the Approved or Pending label for an entry to be rejected.


3. A dialog box titled as Reject loads. Enter any applicable note in the Notes field, if required.

Fig: 274 - Reject dialog box

4. Upload a relevant attachment, if needed, using the Attachments - Click to upload file button.

Fig: 275 - Attachment upload button

5. Click on the Reject button.

Fig: 276 - Reject button

6. You will get redirected to the listing page. The system will display a success notification at the top. The REVIEW STATUS value changes to Rejected.

Fig: 277 - Rejected success notification

NOTE: An email will get triggered to the user who created the Complaints entry in SurgeONE.ai, when the entry is rejected.

Fig: 278 - Rejected email triggered

1. Click on the vertical ellipsis icon of the ACTION column to reveal the context menu options.
2. Click on the expanded View More option.

Fig: 279 - View More context menu option

NOTE: The View More context menu is available for any listed entry.


3. A dialog box titled as Complaints loads. You can view the entry details as well as the approval / rejection notes and attachment filenames here.

Fig: 280 - Dialog box loads after clicking on View More context menu option

8. Outside Accounts

× Use this Outside Accounts module to disclose all outside accounts in which ownership is held.

It is the sixth module present in the grid view of the Code of Ethics page. The following sub-sections explain in detail the associated functionalities.

Click on the View More option of the Outside Accounts module.

Fig: 281 - View More option of the Outside Accounts module

The following image shows the screen that loads.

Fig: 282 - Outside Accounts module Recent Listings

8.1. Outside Accounts > Create New Entry

1. Click on the + Add New Entry button of the Outside Accounts listing screen.

Fig: 283 - Add New Entry button

The following image shows the screen that loads.









Fig: 284 - Outside Accounts > Add New Entry

2. Click on the Employment Date field to load the calendar. Select the appropriate start date. You can make past, current or future-dated selection here.

Fig: 285 - Employment Date calendar selection

3. Enter the name of the firm in the Firm Name field. It is an optional field.

Fig: 286 - Firm Name field

4. Select the relationship of the account holder with the employee who is making this entry. From the Employee Relation dropdown you can select either of the following options - Self, Spouse, Child, Family, Trustee and Others.

Fig: 287 - Employee Relation dropdown

5. Specify whether the account is open or not. If the answer is yes, then enable the Is the account open? slider. It is an optional field.

Fig: 288 - Is the account open? slider

NOTE: Depending the above slider selection, you can provide account details. The following image depicts that after slider selection, the two fields get enabled.

Fig: 289 - Selected slider enables following two fields




6. Enter the account number of the outside accounts in the Account Number field.

Fig: 290 - Account Number field

NOTE: By default, it is a disabled field, but it becomes an enabled, mandatory field when the Is the account open? slider is enabled.

Fig: 291 - Selected slider enables following two fields




7. Select a suitable type of the outside account in the Account Type dropdown. The provided options are Brokerage, IRA, 401(k), Managed, 529, 403(b) and Equity.

Fig: 292 - Type of Account dropdown

NOTE: By default, it is a disabled field, but it becomes an enabled, mandatory field when the Is the account open? slider is enabled.

Fig: 293 - Selected slider enables following two fields




8. Click on the Add Entry button below it to store the entry as specified.









Fig: 294 - Add Entry button to add details

9. The new entry gets listed in the grid view. The above fields become blank. You can add more entries if you want.









Fig: 295 - Added new entry row

10. Select the I attest that this is a complete list of entries and this data is accurate to the best of my knowledge checkbox at the bottom. The Submit button gets enabled.



Fig: 296 - Added new entry row

11. Click on the Submit button add this new entry. You will get redirected to the Outside Accounts Recent Listings page. The new entry is visible in the grid view. The REVIEW STATUS column displays the PENDING status. The system also displays a success notification at the top.



Fig: 297 - View of new entry added to recent listings and success notification

NOTE:

Validations employed

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• If you click on the Add Entry button and have not entered data in all of the mandatory fields, then the system will prompt appropriate validation tooltip below the concerned field(s). There can be two scenarios applicable for this validation. If the Is the account open? slider is disabled, then the following validations are applicable for the mandatory fields.

Fig: 298 - Field validation tooltips displayed when the Is the account open? slider is disabled

• However, when the Is the account open? slider is enabled, then additional validation is applicable for two more fields.

Fig: 299 - Additional field validations for Account Number and Account Type fields when the Is the account open? slider is enabled


Edit an entry

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• If you add a new entry but are yet to submit it, and you click on the vertical ellipsis icon of the Action column, then a context menu loads. Click on the Edit option.

Fig: 300 - Edit context menu option

• The below screenshot has four numerical values indicated in it. The following points correlate with these values.
  1. The fields become populated with the entry details and are editable. You can modify any provided value.
  2. Two buttons labeled as Update Entry and Cancel can be found below the fields. Click on the former to save any modifications made. Click on the latter to abort making any changes and leave the entry unedited.
  3. The context menu options are inactive during entry editing.
  4. The I attest that this is a complete list of entries and this data is accurate to the best of my knowledge checkbox becomes greyed out.

Fig: 301 - Various UI aspects while editing an entry


Delete an entry

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• If you add a new entry but are yet to submit it, and you click on the vertical ellipsis icon of the Action column, then a context menu loads. Click on the Delete option.

Fig: 302 - Delete context menu option

• The entry gets removed.

Fig: 303 - Added entry removed after clicking on the Delete context menu option

8.2. Outside Accounts > Other Associated Functionalities

Permitted user can perform additional activities such as searching for added entries, approving a new entry, rejecting a new entry and viewing more information. Each of these activities have been briefly explained below.

1. Enter the name of any existing Outside Accounts entry in the search bar.

Fig: 304 - Search bar

2. To further drill down search operation results, select an option of the Review Status dropdown. The following options are provided - All, Pending, Approved and Rejected.

Fig: 305 - Review Status dropdown options

3. Search results can be seen if matching entries are found.

Fig: 306 - Search results

A No matching records found label can be seen in the grid view, if no results are found from the search operation.

Fig: 307 - No search results found

NOTE: Search is executed based on the following parameters (displayed in the grid view as the column names).

• EMPLOYEE NAME
• EMPLOYMENT DATE
• FIRM NAME
• EMPLOYEE RELATION
• ACCOUNT NUMBER
• ACCOUNT TYPE
• REVIEW STATUS
• ACTION

All the columns except for ACTION are sortable.

1. Click on the vertical ellipsis icon of the ACTION column to reveal the context menu options. Approve and Reject buttons are only available to people with appropriate permissions.
2. Click on the expanded Approve option.

Fig: 308 - Approve context menu option

NOTE: The REVIEW STATUS column must show the Pending label for an entry to be approved. A rejected entry cannot be approved.


3. A dialog box titled as Approve loads. Enter any applicable note in the Notes field, if required.

Fig: 309 - Approve dialog box

4. Upload a relevant attachment, if needed, using the Attachments - Click to upload file button.

Fig: 310 - Attachment upload button

5. Click on the Approve button.

Fig: 311 - Approve button

6. You will get redirected to the listing page. The system will display a success notification at the top. The REVIEW STATUS value changes to Approved.

Fig: 312 - Approved success notification

NOTE: An email will get triggered to the user who created the Outside Accounts entry in SurgeONE.ai, when the entry is approved.

Fig: 313 - Approved email triggered

1. Click on the vertical ellipsis icon of the ACTION column to reveal the context menu options. Approve and Reject buttons are only available to people with appropriate permissions.
2. Click on the expanded Reject option.

Fig: 314 - Reject context menu option

NOTE: The REVIEW STATUS column must show the Approved or Pending label for an entry to be rejected.


3. A dialog box titled as Reject loads. Enter any applicable note in the Notes field, if required.

Fig: 315 - Reject dialog box

4. Upload a relevant attachment, if needed, using the Attachments - Click to upload file button.

Fig: 316 - Attachment upload button

5. Click on the Reject button.

Fig: 317 - Reject button

6. You will get redirected to the listing page. The system will display a success notification at the top. The REVIEW STATUS value changes to Rejected.

Fig: 318 - Rejected success notification

NOTE: An email will get triggered to the user who created the Outside Accounts entry in SurgeONE.ai, when the entry is rejected.

Fig: 319 - Rejected email triggered

1. Click on the vertical ellipsis icon of the ACTION column to reveal the context menu options.
2. Click on the expanded View More option.

Fig: 320 - View More context menu option

NOTE: The View More context menu is available for any listed entry.


3. A dialog box titled as Outside Accounts loads. You can view the entry details as well as the approval / rejection notes and attachment filenames here.

Fig: 321 - Dialog box loads after clicking on View More context menu option

9. Understanding the Past Code Of Ethics Report

× The Past Code Of Ethics Report lets you search for existing transactions or entries made in respect to the various Code of Ethics modules. Set appropriate filters to generate report results as required. You can also export the generated report results.
You can also view the same report from the Reports page. Refer to the following screenshot which shows the View All option of Code of Ethics card. Click on it to load the same report.

Fig: 323 - Past Code of Ethics Report button

1. Click on the Past Code Of Ethics Report button of the Code of Ethics screen to navigate to the report of the Code of Ethics associated modules.

Fig: 323 - Past Code of Ethics Report button

The following image shows the report page that loads. The following columns are present in the grid view - EMPLOYEE NAME, MODULE TYPE, NO. OF ENTRIES, NO. OF REDFLAGS and ACTIONS.

Fig: 324 - Past Code of Ethics Report view

2. Enter suitable text in the search bar based on which you want execute the search operation.

Fig: 325 - Search bar

3. Select the module type from the Type dropdown. By default, all selection is set.

Fig: 326 - Type dropdown options

Search result(s) populate the grid view based on the filters set.

Fig: 327 - Search results generated

NOTE: Search is executed based on the following parameters (displayed in the grid view as the column names).

• All the columns except for ACTION are sortable.
• Only the entries which are either having Status as Approved or Rejected will get displayed in the report.
• Click on the Export button to load the export options (to download a local copy the generated report). Two options labeled as CSV and PDF load below the button. Click on the former to download an excel file or on the latter to download a .pdf copy. The following image shows the view of a downloaded pdf file.

Fig: 328 - Exported Report

• You can click on the refresh icon to reset the report filters.

Fig: 329 - Filters reset

10. Downloading Template and Importing Post-Trade Entries

Permitted user can download the template from the Post-Trades tab and update the downloaded template file. It can be later uploaded into the application as the system automatically parses the trades specified in the file. Each of these activities have been briefly explained below.

1. To download the template file, click on the Download Template button of the Post-Trades tab under Securities Trading.

Fig: 330 - Download Template button

2. The template file gets downloaded. Open it to begin editing it.

Fig: 331 - Downloaded file

1. There are two sheets in the template, labeled as Accounts and PostTrades. Both are blank by default. Refer to the following two screenshots which display the default views.

Fig: 332 - Default Template view - Accounts sheet

Fig: 333 - Default Template view - PostTrades sheet

The following columns are present in the Accounts tab:

1. AccountNo
2. AccountName
3. AccountType
4. AccountRelation

The following columns are present in the PostTrades tab:

1. AccountNo
2. TradeDate
3. SecurityType
4. SecurityName
5. Ticker
6. Action
7. Quantity
8. Price
9. Status
2. Enter the valid account number under the AccountNo column of the Accounts sheet. You can add multiple row entries.
3. Enter the valid account name under the AccountName column of the Accounts sheet. You can add multiple row entries.
4. Select the applicable account type from the provided dropdown options under the AccountName column of the Accounts sheet. Proceed to make selections for each of the row entries provided.

Fig: 334 - Provided options under the AccountName column

5. Select the applicable account type from the provided options under the AccountType column of the Accounts sheet. Proceed to make selections for each of the row entries provided.

Fig: 335 - Provided options under the AccountType column

Here is a sample view of data populated in the Accounts sheet. Next, proceed to the PostTrades sheet.

Fig: 336 - Sample view of data populated in the Accounts sheet

6. Select a value from the AccountNo options of the PostTrades sheet. The values which are populated under the AccountNo column of the Accounts sheet are displayed in this dropdown. Proceed to set for each of the row entries provided.

Fig: 337 - Set sample options of the AccountName column

7. Set the trade date using the calendar of the TradeDate column of the PostTrades sheet. Proceed to make date selections for each of the row entries provided.

Fig: 338 - Set sample trade dates of the TradeDate column

8. Select appropriate SecurityType column values. The following values are provided as options:

Fig: 339 - Options of SecurityType column

9. Select appropriate SecurityName column values. The options load based on the selection of the previous column.

Fig: 340 - Options of SecurityName column load based on the SecurityType selection

10. After security name selection, the Ticker column values are auto-populated.

Fig: 341 - Auto-populated ticker

11. Select either Buy or Sell option in the Action column.

Fig: 342 - Buy or Sell Action

12. Enter the traded quantity in the Quantity cell.
13. Enter the price at which the trades were executed in the Price cell.
14. Set the Status column to Pending Request.

Fig: 343 - Pending Request Status

Here is a sample view of data populated in the PostTrades sheet. Save the excel file to import its dataset into SurgeONE.ai.

Fig: 344 - Sample view of data populated in the PostTrades sheet

3. Importing Populated Template Dataset into SurgeONE.ai

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1. Begin to create a new post-trade. Click on the + Post Trades button of the Post-Trades tab under Securities Trading. Proceed to provide relevant details in the ADD ACCOUNT DETAILS tab and proceed to the ADD PRE-TRADES tab. Click on the Upload Trades button.
2. The following UPLOAD TRADES modal window loads. Click on the Click to upload file button.

Fig: 345 - Uploading Trades

3. Browse the populated file and then click on the Continue button. The template file gets uploaded if validations are passed. Here is the view of the parsed dataset.

Fig: 346 - Imported dataset visible in UI

NOTE:

• Validation errors can be prompted if the imported dataset is not appropriate.

Fig: 347 - Validations prompted on the sample dataset which was uploaded

• You need to attest the imported dataset in the TRADES ATTESTATION tab.

Fig: 348 - Imported Trades Attestation view

11. Understanding Red-Flagged Entries

Red flagged entries can exist in the Code of Ethics modules where rules are applicable and are set.

1. As mentioned previously in this user guide, rules can be set for Gifts, Political Contributions and Outside Business Activities, at the transactional and time period levels. In this example, let us illustrate that a Political Contributions rule is set, as displayed in the following screenshot.

Fig: 349 - Setting Rule for Political Contribution

2. Now, consider that an entry is made for the Political Contributions module, where the entry amount is more than the transactional limit set, but less than the monthly limit. After this entry is added, the More Info modal window displays the red flag information. The approval or rejection of this red-flagged entry depends on the discretion of the reviewer.

Fig: 350 - Red flag information visible when viewing more info of an entry

3. The same is reflected in the Compliance Overview Report under Reports. The following screenshot displays the number of red-flagged entries found.

Fig: 351 - Reg-flagged items count displayed in Compliance Overview Report

4. Click on the above-marked Code of Ethics row to navigate to its detailed view.

Fig: 352 - User and date-wise entry view