Ann: Agreement with C14 Consulting Group, page-152

That comment seems accurate for at least for director but a long way off for some others.

For context in early Oct 2018 the company made comments which appeared to suggested to most here that they expected to enter commercial negotiations shortly. This appeared to be the catalyst for trading which sent the SP through the roof.

For additional context, all of the options held by the BOD were due to expire Nov 30, ie approx 7 weeks after this announcement. They were all 6c options with the exception of MM who held a massive pile of 15c and 18c options (5m in total).

If the BOD believed the commercialization comments then they had approx 7 weeks to find the funds to exercise their options. No great urgency since you would think they would be keen to exercise then sit on the freshly printed new shares till the $1 party. If they intended to do this then reason suggests that there would be no reason to hand over their cash for another 6 weeks and the daily machinations of the SP would make little difference.

But the record shows that most directors showed great apparent urgency to not only exercise but also to take profits off the table rather than exercise and hold. Their urgency suggested that some didn't believe that the SP would hold up. Not at all what the market took from published management comments in previous weeks.

So let me throw some details at you here. Here are some of the published transactions from one director (approximated):

On about Oct 23: Sold 3.5m shares @23c for approx $818,000 - (nothing apparently to do with options or specific related tax).
A week later on Oct 30: exercised 1m options for $60k then immediately sold 1m shares for $180k - (tax bill for this estimated at only $30k).
Then on Nov 20: exercised 1m options and sold approx another 2.6m shares for approx $520k.

In total this one director put in approx $120k to exercise 2m options but sold approx about 7.1m shares in that same period for about $1,500,000. It would be an outrageous stretch of the imagination to suggest that the vast majority of shares sold were related to funding for exercise of options or the tax associated with funding these. This one director appears to have taken approx $1.4m off the table in the weeks after the letter to shareholders.

I won't go into the details of all the them because each one is different.

I would also bring to your attention that specific dates on which some of these transactions appear to have been made. More specifically the fact that the company later disclosed that some of this occurred during a closed period, at least one of which appears to have been on the day prior to the price sensitive announcement finally disclosing a long list of concerns by the ASX and the company responses. Interestingly the original ASX letter to Biotron is dated Oct 25 however the market was unaware of this until approx 11am on Oct 30, a day after a separate announcement states that clearance was provided.

What was the urgency to seek and receive clearance to trade during a closed period with an uninformed market and a full month remaining before the options expired? Why could any transactions not wait until at least 24 hours after the market was informed about the ASX concerns?



I have no problems with the BOD making a profit on their holdings or options like any other holder. What irks people is when the company makes public comments that suggest they are on the verge of great things then BOD members taking profits that most think would likely not have been possible had those same comments not been made. Its the apparent urgency with which many of the trades strongly suggests that some did not believe that the greatness was just around the corner. Seeking clearance and trading during a closed period, again with no apparent pressing deadline is also concerning and difficult to explain.

Remember that the average investor had no detailed knowledge of the state of play, level of expressed interest etc from BP and only had the apparent confidence expressed in the Oct 9 letter to go on.

From what I can see only one director chose to use this massive windfall event to increase their equity in the company whereas some others appear to have taken the opportunity to maximize their profit during a short window before the SP collapsed.

All IMHO only