I'll give the benefit of the doubt on this
His shareholding is split in two, personal account and super account
You can see that the Brown's holdings are also reported separately here
Neither of PB's holdings alone would result in a pro-rata allocation of more than 450k options (if entitlement was taken up in full), which would leave him out of top 20 option holders
Ann: Entitlement Issue closes raising $8.8M, page-56
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