agm and analysts view, page-5

Don't they only have to make a substantial holding announcement when:
- they become a substantial holder (5% or more)
- when they cease to eb a substantial holder
- or when the change in their shareholding is 5% or more of the issues shares of the company (i.e. they would have to sell 22.3m shares in this case).

Could be wrong, but this is my understanding. Perhaps why Batavia didn't report either.