Luk may do well to refer to BRM's code of conduct. I'm not saying he is insider trading, just like he said his mates, wives, pet dogs etc. were not associates when they were holding shares.
2. Use of Confidential or Inside Information 2.1. Australian securities laws prohibit any person who has material non-public information (important news that has not been disclosed publicly in a press release or otherwise) concerning a company whose securities are traded on the public markets from purchasing or selling securities of that company, or from communicating non-public information to any other person under circumstances in which it is reasonably foreseeable that such person is likely to purchase or sell such securities based on such disclosure.
2.2. An employee may acquire confidential information concerning Brockman or any other party with whom Brockman is or may be dealing during his/her normal job activities or from other employees. The employee must treat this as privileged information and not repeat it to anyone outside Brockman, who has not been authorised to receive it. For example, no employee may reveal confidential information or data relating to exploration or mining activities or properties, proposed acquisitions, mergers or other material business transactions, financial data, including revenues and earnings, information regarding major management changes or other important and confidential data or information regarding Brockman.
2.3. Such confidential or inside information is to be used solely for Brockman’s purposes and not as the basis for personal gain by the employee, his/her family or friends. An employee (including his/her family) may not, therefore, while in possession of such confidential data or information, engage (directly or indirectly through accounts which he/she controls or in which he/she has an interest) in transactions with respect to Brockman’s stock or shares or interest in other companies or organisations, the value of which is likely to be affected by any dealings between such organisation and Brockman. Such restrictions shall apply until such data or information has been released to the public and sufficient time has passed to allow investor reaction. Any infraction could subject the employee to civil and/or criminal liability under Australian Securities Law.
