Ann: Change in substantial holding, page-22

So, considering my previous post in regards to black out periods and policy and your comments above relating to Asic and policing share purchases of directors etc.

its really quite easy for them to police insider trading.

1) for a company to obtain listing on asx there are a whole bunch of policies required to be approved such as a policy as is mentioned in my previous post
2) there will be traceability in the form of minutes of board meetings and communications via email etc both internally and externally which provides evidence when sensitive information became known/made available

im not saying insider trading doesnt exist in fact it is probably rampant BUT in regards to your comments some level of colusion would be required both internally and/or externally from the company to avoid. prosecution of insider trading. In this particular case I dont think 20k in a share purchase by a director is to considered.

I think what is more likely is Simmons believes the current sp is a steel and thats his only reason for on market trade in this circumstance.