King United Beef Holdings Ltd (KUBH) is a company which owns a number of cattle stations throughout

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King United Beef Holdings Ltd (KUBH) is a company which owns a number of cattle stations throughout New South Wales. KUBH has a board that consists of four directors, Charles, Camilla, Andrew and Edward. It currently has $ 100 million in capital, on deposit with a NSW Bank. The board has decided that given its healthy cash position, it wants to expand the company's operations.

The board of KUBH decides that, to make its operations more profitable, it should sell some of its lower-producing farms, and gives Edward the authority to identify which properties should be sold and to sign contracts of sale, without reference back to the board. Edward identifies five farms, and sells four of them to other agricultural firms. The fifth farm he sells to Charles' son, William. The farm is sold at market value.

The board of KUBH sends Camilla as its representative to the annual Agriculture Leaders Conference held in Bathurst. In between one of the conference sessions, Camilla meets up with Paul, who works for an agricultural co-op. He says to her "So, how are things going at KUBH? You guys are doing well aren't you? You might be interested to know that there is a fantastic grazing property across the border in Queensland that is being sold by Oz Beef Ltd". Later during the conference, Camilla meets up with the Managing Director of Oz Beef Ltd and offers to find out about the property. After getting back from the conference, she registers a company, Camilla's Cattle Pty Ltd, in which she owns all the shares and of which she is Managing Director. Camilla's Cattle Pty Ltd buys the property from Oz Beef Ltd, and in the first year of its operation, makes a profit of $1 million.

Andrew has a wide circle of friends. One day he receives an email from one of them, Mary, who writes "Guess what?!!! I have been elected to the board of New Grain Cattle Feeds Ltd!! I take office in January 2023." Andrew writes back "Fantastic!! Let me know if I can help you in any way." Mary in turn answers "Actually there is something you can do for me. Once I am on the board, could you let me know what price KUBH is willing to pay for cattle feed from time to time?" Andrew responds "Of course! Anything for a friend. Let me know as soon as you join their board and I'll start sending information."

Another agricultural development company, Republic Holdings Ltd, has been buying up shares in KUBH, and now holds 47% of KUBH's shares. Most of the shares have been sold to Republic Holdings by investors who are dissatisfied with the way in which the board of KUBH has been running the company. Republic Holdings itself has made no secret of its view that, if it gained control over KUBH, it would elect a new board. After hearing about this, the board of KUBH contacts Crown Farms Ltd, a major shareholder in KUBH, who has been happy with the board's performance, and offers to issue Crown Farms Ltd with $4 million worth of shares, which Crown Farms Ltd accepts. The KUBH board minute approving the sale stated that it had been entered into because there was a need to increase KUBH's capital reserves. The share issue results in Republic Holdings Ltd holdings in KUBH being reduced to 39%.

Assume that it is October 2022 and you are an ASIC investigator appointed to look into the affairs of KUBH. Assume all the above facts have become known to you and that they would all be provable in court.

Using the ILAC model of legal writing, give your best advice on what specific issues are of interest to the market regulator, and what remedies might be available to ASIC in the case of each separate issue, citing statutory and relevant case-law authority.