But ASX Regulatory Guide (RG 5.286) says a substantial holding disclosure is required when:
(b) has a substantial holding and there is a movement of at least 1% in their
holding
2.545 mio shares are more than 1%. Therefore if it had been TBR, they would have had to announce it.
Furthermore I think that Mr. Billis would also have had to issue a "change of director´s interest notes" in case TBR had sold.
Both did not happen. Therefore I stick to my opinion that it was not TBR who sold.
Ann: ASIC Form 484 - Cancellation of Shares, page-4
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