Ah. So he was offended by the insinuation and then admitted he did it. It would have been easy to test the truth of the statement by reviewing the transactions and looking to see if they were tagged with whether they were solicited or unsolicited. All trades carry that information. He may not know that!
Well, assuming the facts are as expressed - and in a functional review system - he ought to be toast. It's trading on inside information regardless of the scale of the transaction. Criminal offense.