Hi Poohbear, I know it can be tempting to think along these...

Hi Poohbear, I know it can be tempting to think along these lines at times and whilst it cannot be ruled out entirely…..imo it is extremely unlikely that this is the cause. But to your question, I doubt ASIC would be monitoring lab employees or related parties unless they have reason to.

Other than being against company policy (so what I hear people saying), most labs have audit trails and online monitoring systems in place. ALS (who DRE are using) have the webtrieve system, this allows near real time batch/sample tracking for the client including what stage of the analytical process each sample/batch is, preliminary results as they come off the machine, and the names of lab personnel involved.
DRE will also be regularly monitoring who is buying and selling…difficult to monitor everything especially with related parties etc but the point is there are checks in place.
Same goes for DRE employees, they will be given trading windows, approved by the BOD, usually immediately following a material announcement when they are considered to not be in possession of any undisclosed material info. With the activity onsite, I suspect employee trading windows would be nearly non-existent.

As a general statement across the industry as a whole - there is far more potential for ‘grey areas’ when it comes to institutional entities being provided project updates from management. Obviously, these shouldn’t include any non-disclosed ‘material’ information, but even just more detailed relative timing updates, changes in sentiment or thoughts from management can be very insightful. Whilst this might be technically ok, imo it is a clear advantage for those involved.