"senior managers may be deemed to have “inside information”...

"senior managers may be deemed to have “inside information” about the status of evolving contract negotiations which cannot yet be disclosed."

This is a very, very weak argument. Let's just say it's true for a minute. So why were they not buying 4 months ago when obviously there were no major contracts being negotiated (based on the fact we have not had any major contracts signed since then)?

The market is fully aware we are bidding on numerous contracts around the world at any point in time. The winning of these contracts are not within management's control so the timing is not known by them. If a very significant contract is being negotiated which would surprise the market and take us more than 10% beyond the revenue estimates, then it could be argued as insider trading . But this is extremely unlikely (as evidenced by the last 12 months business activity).

Basically he has argued the directors and senior management can never buy shares. Very convenient, but also very disingenuous. I assume then they can never sell shares as they may know we are not negotiating contracts that the market expects we should be negotiating to meet the expected revenue . Just ridiculous, imo.

Ps. thanks for your efforts to contact management and share the response