33(as defined in section 118B of the Act) a person who has inside information:
- (a) as a result of his membership of the administrative, management or supervisory bodies of an issuer of qualifying investments;
- (b) as a result of his holding in the capital of an issuer of qualifying investments;
- (c) as a result of having access to the information through the exercise of his employment, profession or duties;
- (d) as a result of his criminal activities; or
- (e) which he has obtained by other means and which he knows, or could reasonably be expected to know, is inside information.