flushing out the substantial holder

Did some research on the requirements for notification of substantial holdings....

section 671B of the Corporations Act requires that any holding that exceeds 5% of issued shares requires notification within 2 business days of the transaction. Likewise any change in substantial holdings of more than 1% needs to be notified.

The XTOS from 7th Jan by my calcs represents 5.34% of issued shares and prima facie the lack of notification could constitute a breach of the Act. I have just sent a query to ROC investor relations. Let's see what response I get.