Kenny works as a legal executive at Chan & Co. (“C&O”) which provides legal serv
Kenny works as a legal executive at Chan & Co. (“C&O”) which provides legal services to Kool Resources Ltd. (“Kool”), a company listed on the Hong Kong Stock Exchange. On 1 st August, when Kenny attended a meeting at Kool, he overheard a conversation between Benny (the managing director of Kool) and Edmund (the finance director of Zan Resources Ltd. (“Zan”)). Zan is a long standing business partner of Kool. The conversation revealed that Zan will soon launch a take-over bid for Kool’s shares. Kenny resigned as an employee of C&O on 2nd August and bought 5,000,000 shares of Kool. Kenny also told his friend Cheryl, who was holding 15,000,000 shares of Kool, about the potential take-over bid. However, Cheryl believed that the share price of Kool might go down after the takeover and decided to sell all her 15,000,000 shares in Kool to Kenny. The shares were transferred to Kenny on 4th August. On August 5th, Benny was interviewed by David, a journalist from a local newspaper. During the interview, Benny accidentally told David about the potential take-over bid by Zan for Kool’s shares. After the interview, David ringed his wife Anna, asking her to buy 100,000 shares of Kool. Zan announced its take-over bid for Kool’s shares on 10th August. The share price of Kool rose by 15% after the announcement. Required: Advise Kenny, Benny, Cheryl, David and Anna whether they have engaged in insider dealing under the Securities and Futures Ordinance.

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