RE:RE:RE:RE:RE:RE:Spark of life in the USA Section 1.1 of the Ontario securities commission states (https://www.e-laws.gov.on.ca/html/statutes/english/elaws_statutes_90s05_e.htm#BK0):
“insider” means,
(a) a director or officer of a reporting issuer,
(b) a director or officer of a person or company that is itself an insider or subsidiary of a reporting issuer,
(c) a person or company that has,
(i) beneficial ownership of, or control or direction over, directly or indirectly, securities of a reporting issuer carrying more than 10 per cent of the voting rights attached to all the reporting issuer’s outstanding voting securities, excluding, for the purpose of the calculation of the percentage held, any securities held by the person or company as underwriter in the course of a distribution, or
(ii) a combination of beneficial ownership of, and control or direction over, directly or indirectly, securities of a reporting issuer carrying more than 10 per cent of the voting rights attached to all the reporting issuer’s outstanding voting securities, excluding, for the purpose of the calculation of the percentage held, any securities held by the person or company as underwriter in the course of a distribution,
(d) a reporting issuer that has purchased, redeemed or otherwise acquired a security of its own issue, for so long as it continues to hold that security,
(e) a person or company designated as an insider in an order made under subsection (11),
(f) a person or company that is in a class of persons or companies designated under subparagraph 40 v of subsection 143 (1); (“initié”)
By this definition there are several types of insiders, ones that are such by virtue of their access to confidential company information (directors,officers, even some employees/family members of the company), and there are insiders who are such by virtue of the number of shares they own, and these may not be privy to confidential information. Disbrow falls into the latter- as far as I know he is merely an investor at Haywood who has a particular fondness for NIko for whatever reason. If there was a blackout period due to the imminent release of material information he would not be affected. He could keep buying during the blackout, because I don’t think he’d hear about the info until it was material. Anyone who is working fro Jeffries (the company helping NKO sell their assets) would be prevented during the blackout.