Ann: AGM Presentation, page-130

I can't think of a rule that would require them to disclose how many need to be sold. I think it would be up to the company to decide whether they want to release that or not. If it was a buyback they would have to disclose.

I can't recall whether I've seen such a small company undertake this exercise before. You're right though, selling that many shares when daily volumes aren't great will either impact the share price or result in the date they expect it to close getting pushed out to allow extra time. On the flip side, holders should understand where the volume is coming from.