This is a rare occasion where it is not scare tactics- just...

This is a rare occasion where it is not scare tactics- just obligations to disclose under 2 different pieces of regulation which operate independently, and with different deadlines. Here- since the PGH substantial shareholder is also a PGH director- they tend to track each other closely, but not exactly.

App 3Y is required for directors under the Listing Rules (as you say within 5 business days): previous one was published on 30/1 covering trades from 23-29 Jan. Today’s 3Y covers trades from 30/1 to 6 Feb. This must be disclosed even if the trades are tiny.

The notice 2 days ago was not a 3Y but the substantial shareholder movement- required under the Corporations Act. “[During a takeover] the bidder must notify the ASX by 9.30am on the next tradingday, whenever there is a movement of at least 1% in the bidder's holding”. Ie must disclose immediately the holding changes by more than 1.00% from the previous sub sh notice.

RG’s interests changedto 85.12% on Friday 2 Feb, and that was disclosed on next trading day being Mon5 Feb. The latest 3Y today showed a holding of 85.39% at COB yesterday 6 Feb. Thus he acquired 0.27% on Monday and Tuesday. These must all have been acceptances off market, since there were no shares traded at 84c on market.