I have tested this film quite intensively when it was introduced in 2016. My tests of the chararcteristic curve and my comparisons to my former Agfa Aviphot Pan 400 tests showed me immediately that this "new" film wasn't new at all, but just former Aviphot rests.
The extremely strong and problematic S-shape curve you have got is absolutely typical for this film type. Very difficult to handle.
It isn't perfectly clear because it is very old, long expired film, which has meanwhile a quite high base fog (and reduced real speed due to its age). Being at least 12 years old former Agfa ASP 400s = Aviphot Pan 400. A friend of mine worked in aerial photography professionally at that time: In 2008 Agfa informed their aerial customers that this film was coated that year the last time, and that the film is discontinued.
Bellamy Hunt (JCH) has unfortunately lots of criminal energy. He is cheating his customers for years.
Instead of delivering fresh film - as claimed by him - he has just taken some old, expired leftover film stock and sells it totally overpriced.
And selling this film as ISO 400/27° is another cheating. As others have correctly described here, this films has a real speed only in the 40 to 100 range, dependant on the devlopers in use.
When this film was introduced lots of very experienced photographers tested it. And realized that it was just repackaged old Aviphot Pan 400 / ASP 400s.
They published their results and were promptly attacked by Bellamy Hunt and his partner Vishal Soniji from camerafilmphoto. Both continued telling their stupid marketing lies.
In 2017 Mr Hunt published an article that he has for the first time in his life developed a BW film at home by himself. And that he is a complete rookie in processing films.
And the same guy has a year before bashed very experienced photographers with decades of experience in film processing - including evaluating films with densitometers testing the characteristic curves and real speeds. He has bashed them because they have told the truth about his film repackaging and cheating.
This demonstrates very clearly what an as.........le this guy is.
Lying at his customers and ripping them off is his business.