RE: Scallywag drilling8 Feb 2021 09:26
@napth
You are mistaken, I'm afraid. GH is more "inside" at GGP than NCM and he bought shares, so I think we can safely assume they could, as well.
1. There will be times when they don't have any unreported results at all and they could instruct a broker to buy on their behalf at that point in time.
2. There will be times when they don't have any unreported results of any real significance and they could instruct a broker to buy on their behalf.
3. They could construct a "Chinese wall" where the executives who are making share-purchase decisions are not informed of any new drilling results for a period of time, so that they can make non-insider decisions as to whether to buy or sale.
Also, once the instruction to buy is given, they are in the clear. For instance, if in any of the above situations, they instruct their broker to "please buy 100 million shares over the next month, gradually so as to not cause a spike," then they are in the clear. They've given their instruction, and can make it irrevocable. If then they get further inside information after that point, it doesn't matter, they gave the instruction before they had that info.
So, in short, there are multiple ways in which NCM could acquire GGP shares on the quiet even though they are in a JV, without breaking insider trading rules.