Would exercising expiring warrants really constitute insider trading?

Yes Insiders exercising options is insiders buying more shares.

They didn't let them pass by (they would only do that if the share price was lower then the option price, and that's not the case).

If the insider didn't have money, they would have sold shares at 1.38 to buy the options at 97 cents, thus own more shares. They didn't sell any.

You would first see the filing on SEDI and then you would see it on Canadian Insider the next day. (we have seen nothing on SEDI)

The only reason they have not exercised their options is because they can't. Why ? Because they're blacked out.

I called and asked what happens in this situation, they said the options get pushed forward and insiders can exercise them within 10 days of the blackout removal.