Selling off-market at a discount would seem unethical, at least...

Selling off-market at a discount would seem unethical, at least to me anyway. Selling the shares off-market at such a premium would, IMO, be very unlikely. I think a 5-day VWAP, or something along those lines, would be more likely.

I'm not privy to those discussions/negotiations, so I really have no idea, but that's my thinking anyway.

The sale agent is a large shareholder in their own right, I wonder if there is any possibility of them buying some or all of the remaining shares of the ineligible shareholders. A conflict of interest no doubt but perhaps there is some possibility there.