I thing Mgmt is very much avoiding an SEC fine. This is a small biotech that could have huge stock price movement for reasons the insiders would not be able to predict. It would raise a huge red flag if Nader bought stock and the next day Brazil said send us all the product you got. Nader and the other employees/BOD is constantly getting what would be considered inside info and if they bought personally they would certainly need legal advice of how to not get fines into oblivion. This is why they go the route of a planed employee compensation system to avoid anything that looks questionable.