Ann: Appendix 3Y x 2, page-3

Ordinarily, I would agree with you.

But there is something not quite right here.
On the 3Y form, in the box marked 'nature of change' it states that shares were acquired under the SPP.

The Share Purchase Plan offer:

'The SPP Offer The SPP is offering up to 18,750,000 of Shares (New Shares) to raise up to $3.0 million and entitles Eligible Shareholders, irrespective of the size of their shareholding, to purchase up to $15,000 worth of New Shares at a price of $0.16 each.'

The document explicitly states a maximum applicable to all eligible shareholders, irrespective of size.

How did both of these directors manage to avoid this rule?

Given the thing was undersubscribed the question that most would ask is 'does this really matter?'
Well, in my mind, yes it does as it goes to governance and fairness.
Ordinary shareholders have never been considered by the Board, and look at the issuance of options to the Board......Low hurdles, lengthy expiry, and issued when the project has been considerably de-risked from a time of a few years back prior to the granting of approvals and cornerstone investment.

Here's another question......were the Board members offered loans by the Company to purchase these shares?....if so ...what are the terms?

But ...notwithstanding such questions my cynical brain considers, I'm still quietly confident of making some money from this project.