You are not basing that on any actual rules or regs, just based on what you think.
Insider info has nothing to do with vesting period. And no a consultant does not become an insider/affiliate.
Consultants can sell shares based on accelerated vesting and not subject to normal vesting rules required for insiders.
The funny thing though is, so is that convertible debt really not with a 3rd party? As by your definition a 3rd party could be considered an affiliate.