Blackout as of Nov 30 - is that right? That should have happened way before the event. There are two issues - one regarding the technicality of the group plans and their holdings (addressed); another regarding deal confidentiality and insider trading. The spin-out has obviously been a catalyst of sorts - management and directors, and their advisors, should have been subject to blackout well before the event, no?
Maybe I'm reading too much in there, but it seems odd that they wouldn't have mentioned the internal black-out in the filing - as there is no strict obligation to announce black-outs generally - to avoid (my) confusion.