@kellectric, your question is interesting, but I concur with other commenters: "Nothing to see here." Nevertheless...
ASX requirements regarding trading by key management personnel (KMP) are included in ASX Guidance Note 27.
https://www.asx.com.au/documents/rules/gn27_trading_policies.pdf
Some noteworthy points:
1. KMP will often hold inside information. Trading based on insider information may breach the Corporations Act 2001 (Cth).
2. Each company is required to have a trading policy (to comply with Listing Rule 12.12.1), which includes information on the closed periods.
3. Trading policies are always subject to the overarching prohibition against insider trading, even if a person receives clearance to trade in securities, whether or not under exceptional circumstances, or trading falls within an exception under the policy.
4. If the ASX has any reason to suspect that a person has committed a significant contravention of the Corporations Act 2001 (Cth), it is required under s.792B(2)(c) to give a notice to ASIC with details of the contravention.
Ann: Appendix 3Y, page-47
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