There is an Atomo Diagnostics Share Trading Policy which Mr Kelly would have to have followed (see https://cdn-api.markitdigital.com/apiman-gateway/ASX/asx-research/1.0/file/2924-02242840-2A1229769?access_token=83ff96335c2d45a094df02a206a39ff4). Nevertheless, his 'sell off' - as others have noted - represents a very small margin of what he presently owns.
AT1 FY21 - General Discussion + FA, page-1813
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