Thanks Lux. I didn't say it was deliberate manipulation. I...

Thanks Lux. I didn't say it was deliberate manipulation. I merely recited the events that occurred with questions that those events raised in my own mind. Its upto each person to study the events and reach their own conclusions armed with the specific details.

People should also be aware of insider trading laws. They are very interesting because I understand that they specifically refer not just to buying and selling but many forms of "dealing in securities", including options. What is also interesting it that the publishing of a price sensitive announcement is not necessarily the point at which an insider is cleared to trade (or deal) in the companies securities. There must be time for the market to digest the information and become informed otherwise insiders could drop an announcement at 10:05am and start selling 30 seconds later before anybody has even had a chance to read it. Insiders often know the substance of the announcement and have days to ponder the ramifications on the share price and their own financial position before the general holder base even becomes aware of the information which may change the value of the securities one way or another.

As an example have a look at this Biotron announcement made on Oct 30 2018 containing detailed and complex issues which took the company 5 days to compile and respond to. One assumes the directors all knew the substance of this letter. How long do you think it would take for the market to reasonably consume this information and for the market to become "informed" before insiders should be allowed to "deal" in the companies securities? Remember the SP dropped by 30%ish in the day or so after this news was finally released.

https://www.biotron.com.au/wp-content/uploads/2018/10/Biotron-Response-to-ASX-Aware-Query.pdf

So would it surprise you to see that a day earlier on Oct 29th Biotron made an announcement about at least executive exercising options. Exercising an option is the purchase of company securities at a below market price, ie the person pays money and receives new shares. Remember that an option isn't a share but merely a right to purchase a share at a specific price before a specific date. More like a discount coupon. Exercising of options is purchasing of shares. Often people exercise options so that they can then sell the shares. One might reasonably ask if acquiring new shares is "dealing in company securities". On Nov 2 the company released a 3Y announcement which included the statement "512,500 fully paid ordinary shares acquired on29 October 2018 by the exercise of 30 November2018 6 cent options" in relation to one director and stipulated that another was dealing in the companies securities on the 30th.

Did they know that it was a closed period that they should probably not be dealing in the companies securities? Based on their own written disclosure on Nov 2 2018 I'd be inclined to believe that they knew of the closed period. Did they do it anyway? Looks to me like they may have.


Again I'm not accusing anybody of anything illegal but it does appear to have a certain pong to it. These are my opinions only based on the published documents which are readily available online on both the Biotron website and via the ASX.