China issues draft guidelines on overseas investment, page-35

The problem is that the board has officially announced that it is actively helping BCC to acquire another 5% of the company both on and off market, and that BCC has had access to the data room, which includes information regarding the recent drilling campaign not yet released to the market. There could not be a clearer case of insider trading if BCC was already buying on market, the only evidence required for an easy prosecution is previous official company announcements and proof of an on market transaction by BCC before drilling results are presented to the market. I seriously doubt BCC or any of its officers would make such an error.