If ADN were to buy MEP shares, the BoD would have to sign off on...

If ADN were to buy MEP shares, the BoD would have to sign off on it. To do so would require they held no material non-public information. There would be times when that was the case but not in the last few months. Breaching the Corporations Act isn't restricted to individuals as you suggest - companies operate with the guidance of their BoD and so the company itself AND the board members would be open to prosecution if they dealt as insiders. If STX & WGO had no material non-public information at the time, or it was a fully announced placement, no issue. How would you feel if you sold your MEP shares to ADN at 11c a few weeks back? Windows are pretty tightly controlled in many companies for the reason you outline.