Asic would definitely like to know if the transactions were...

Asic would definitely like to know if the transactions were deliberate (evil act) or purely ignorant of Australian rule.

Anyway, it looks like penalty is unavoidable as the amount of shares changed hands are quite significant. Now let's us all pray that ASIC doesn't fine the company! (unlikely though). If they do, let' us pray the company keeps growing to offset the difference this year and gives us the dividend. So ASIC needs to fine the deputy chair only! (Hopefully)