KL Limited ("KL") is a leading oil and gas production company listed on the Stock Exchange of Hong Kong ("SEHK"). KL is planning to merge with DW Limited ("DW"), a natural gas production company. For this purpose, KL engaged Sun Ltd as its financial advisor.

In a meeting held on 5 March, KL's managing director Albert briefed the project team of Sun Ltd on KL's plan to merge with DW. Among others, KL's financial controller Sarah and Sun Ltd's vice president Teresa attended the meeting.

Finally on 9 August, KL made an announcement disclosing the merge plan. KL's share price went up by 25% immediately.

Required:

(a) After the meeting on 5 March, Albert passed the meeting notes to his secretary Jenny for filing. Jenny read the notes and placed an order to buy 100,000 KL shares on the same day and sold those shares on 10 August. Did Jenny or Albert engage in insider dealing?

(b) Sarah is going to leave Hong Kong and migrate to Canada. She personally held 10,000 shares of KL. She approached Albert on 6 March, offering to sell all her KL shares to Albert off the market, which Albert accepted. Did Albert or Sarah engage in insider dealing?

(c) Teresa asked her friend Mr Li to purchase HK$500,000 worth shares of KL using his own securities account on 8 August. After the purchase, Teresa transferred HK$500,000 to Mr Li's bank account to settle the payment. Did Teresa or Mr Li engage in insider dealing?