Ann: Aussie Farmers Direct - Administrator Appointed, page-22

look at the recent announcements. They will give you your answer.

ASX 1/2/18:
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In this area, the AHF Board expects in the coming three months, to announce three such separate contracts with established other industry customers. These announcements will likely coincide with product and market launches in major retailers at State and National levels. The details are commercially sensitive for the customers and are currently restricted by confidentiality agreements as is general practice. Revenues / Margins from these projects are expected to more than replace those lost from the recent declines in bottled white milk sales with the first of the three due to commence February 2018 and the third due to progressively roll out from July this year. The sales which are at this stage expected to commence rollout in July and be nationally distributed, have the potential to exceed current factory capacity within the first 12 months and may necessitate some expansion of sections of the relevant processing areas.

Contrast this to ASX 8/11/17:
----To progress this project rapidly the AHF board is assembling a compact group of industry experts to develop the detailed structural and financial Business Plan for the Camperdown Dairy Park and the Group’s further development into specialty products for domestic and export sale where the emphasis will be on specialised markets with high value ‘Own Brand’ products. Target delivery of the first version of the Business Plan is end February 2018. The Business Plan will include more detailed estimates of expected capital costs.

And to 24/10/17:
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The board advises that it is well underway in the implementation of several parts of the strategy published on 14 July 2017. This announcement deals with Camperdown Dairy product transition and development of Own Brands. A further announcement will be made within the next three months about the progress on joint venture plans and funding, which are progressing under several separate confidential negotiations.

And then bring this back full circle through the H18 report of 28/2/18:
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The board intends to make certain announcements imminently of its strategic plan for the Group and in July 2018, of new customer business currently being contracted, the details of which are restricted from disclosure for commercial reasons.

Within this so called secretive time range during which imminent announcements, updates or business case results were all to be announced (so, spanning the period 24/10/17 - 28/2/18), but in fact haven't been, directors engaged in share trading activity (buying, that is), on (as per the ASX announcement dates):
1/11/17 (MH +50,000)
6/11/17 (MH +75,000)
9/11/17 (PS +120,000)
20/11/17 (PS +70,000)
30/11/17 (MH +200,000; PS +100,000)
16/1/18 (MH +100,000)
20/2/18 (PS, per XGM resolution outcome)

So, apart from the 20/2/18 advisory, not certain how the interlinking of blackout periods, retention of market sensitive information, and hints at disclosure of material matters which nonetheless remain undisclosed due either to their sensitivity or to their confidentiality, all come together. Irrespective of this, when language is used to point to an "imminent"announcement, or to updating the market "within 3 months" and the make disclosure dates all pass by without any announcements being made, then you can't have market trading going on without the corresponding disclosure then being made. The two are mutually exclusive.

The best thing then for the Company to do is to actually do as it has said it would do on repeated occasions and that is, make the necessary, proper and responsible disclosures to the market (all of which it has been alluding to since at least 24/10/17 but without any of the hinted at announcements having been made). So, for so long as the commercially confidential information cannot be released to the market, then one would have to argue that the blackout period re: trading, applies and is active (as it has and should have been since 24/10/17, at least).