IMHO (as stated) it's unbelieveable that none of management (other than Brown recently) has purchased shares when trading windows have been open. IR has said that the legal beagles are working on how this can be done given what all is going on with the company. Per their Insider Trading and Disclosure policies there is a required disclosure of material info unless, "...the Committee determines that disclosure of such material information would be unduly detrimental to the Corporation (for example if release of the information would prejudice negotiations in a corporate transaction), in which case the information will be kept confidential until the Committee determines it is appropriate to publicly disclose. In these circumstances the Committee will cause a confidential material change report to be filed with the applicable Canadian securities regulators and will periodically (at least every 10 days) review its decision to keep the information confidential."
This is their only excuse they could possibly have for the lack of disclosure. Could they keep such info quiet this long? Seems hard to believe, but they better have something like this going on which comes out before too much longer or their failing credibility will be at zero.