See Below - from the trading policies The Notification Officer...

See Below - from the trading policies


The Notification Officer will consult with the Chair (or where the Notification Officer is the Chair, with the Board) in the case of proposed Trading by the Chair) in relation to any proposed Trading due to Exceptional Circumstances. Permission to Trade is entirely discretionary, and Employees should not Trade in the expectation that permission will later be given.
If permission to Trade is granted, it will be given in writing and the Employee may only Trade the Securities during the period specified in the permission. A permission expires five business days from its date, unless it specifies a different date.

having just read the above in the trading policy is it not unreasonable to accept that the above is the case ???

If So , I would be very careful in accusing someone of doing something illegal, otherwise is it not possible they  may find themselves in a libel situation ????