Although QPRH was suspended from AIM prior to 2007, it was still bound by the Takeover Code by virtue of the prospectus issued in 1999 (see email sent at 00:23 on 25 August 2007, pages 95 and 96 of AC 1).
Mishcons/Steele were aware of the Takeover Code issues in the sale of the majority stake in QPRH. DM pointed this out to Steele on 6 August 2007 at 14:51, the same day Steele first contacted M. (page 97 of AC 1). De Marco warned that a new buyer exceeding 29.9% of the shares would have to make an offer to all shareholders, taking at least a couple of weeks.
On 9 August 2007, Mishcons was already considering the applicability of the Takeover Code. SMMS partner of Mishcons, suggested in an e-mail at 5:37 p.m. (page 99 of AC 1) that the company’s board immediately contact the Takeover Panel to verify the application of the Code to the transaction, confirming that if a buyer exceeded 29.9%, an offer for all shares would be required at the same price or the highest price paid in the last 12 months.

Mishcons were aware that the purchaser should have launched an offer for all the shares from the outset. If this condition had been acceptable to the purchaser, it would have been appropriate to inform me and formally initiate a new offer, but this did not happen.
In an e-mail of 10 August 2007 at 15:26, MM asked Steele on whose behalf Mishcons was acting (company or selling shareholders?) (page 100 of AC 1). I have not seen Steele’s reply, but it is clear that Mishcons and Steele assumed responsibility for me by preparing the draft contracts on my behalf.
On 13 August 2007 at 07:56, Steele sent an e-mail to DM and P (page 101 of AC 1) stating that the Takeover Code did not apply if unrelated parties bought the shares, although he knew that the buyers were related. Steele informed DM that P wanted to go ahead anyway, regardless of the financial situation.
An e-mail from DM to P with Steele copied on 17 August 2007 at 11:32 a.m. (page 102 of AC 1) confirmed that the Takeover Panel was already involved and was putting pressure on QPRH to announce the sale. However, I was not invited to the 17 August 2007 meeting in London with KS and P and was not informed of the Takeover Code issues.

On 17 August 2007, Steele informed Mishcons of the Takeover Panel’s involvement (e-mail sent at 11:53 a.m. on 17 August 2007, page 102 of AC 1).
On 20 August 2007, an email from Steele to G of Mishcons at 07:21 (page 103 of AC 1) confirmed that, despite the problems with the Takeover Panel, the sale price remained 5 pence per share.
According to a participation note dated 20 August 2007 (page 105 of AC 1), Crawshay of the Takeover Panel confirmed to Steele that the Takeover Code did not apply, based on information received from Steele.
P was only informed of the problems with the Takeover Code on 24 August 2007 (e-mail sent at 15:15, page 106 of AC 1). Steele did not want me to become aware of the Takeover Panel issues.
C S Securities was appointed as financial advisor for the takeover of the vehicle (Sarita) owned by FB.
Beaumont Cornish was contacted late in the day (via C S S ) to act as Takeover Advisor Rule 3 for QPRH (pages 107-118 of AC 1). When Withers asked if the Rule 3 consultant had been appointed, Steele appeared to agree without consulting anyone else (pages 119-120 of AC 1).
A complaint was lodged with Scotland Yard on the matter.