Ann: Ceasing to be a substantial holder, page-9

Looks to me like the incorrect form has been used here?

If im reading this correctly, Unisuper added more to their overall position through an indirect holding which was with Regal??? Chat GPT was asked the following question. Here is the reponse.


how do you interpret this?

Me, I'm thinking Unisuper paid Regal to short this stock and then once they were ready, they purchased it and now they're total holding is 97,4021,778

Your thinking has some creative elements, but let’s break this down using what's actually disclosed in the Form 605.

What the Form 605 Shows

• UniSuper was previously a substantial holder in Botanix with 80,730,536 shares (from 24 April 2025).

• On 9 May 2025, they acquired another 16,672,242 shares, taking their total to 97,402,778 shares.

• The new shares were bought via an on-market purchase, classified as an indirect holding.

• The filing is a Notice of ceasing to be a substantial holder – this seems odd because their total holding increased, not decreased.

Interpreting the Apparent Contradiction

At face value, Form 605 is used when a shareholder drops below the 5% threshold, thus ceasing to be a substantial holder. But here, UniSuper increased their holdings, which suggests this is either:

1. An error in the form selection, and they should have filed a Form 604 (Notice of becoming or changing substantial holding), not a 605.

2. They may have ceased to hold directly, and now hold only indirectly (e.g. via Regal), changing the nature of their interest but not the overall exposure.

So, Did UniSuper Pay Regal to Short the Stock?

Unlikely, based on the information provided.

• Regal Australian Long/Short Fund is referenced in Appendix A, but only in the context of UniSuper acquiring shares via an indirect holding.

• There's no evidence in this filing that Regal was short the stock, or that UniSuper paid them to short it.

• It seems UniSuper may be using Regal as a fund manager or sub-account, and the shares are now held on UniSuper’s behalf within Regal's structure (indirectly).

✅ What You're Probably Seeing

• UniSuper initially held the shares directly.

• Later, they increased their holding via Regal (likely via mandate or fund structure).

• The "ceasing to be a substantial holder" may refer to a change in how they hold the shares (from direct to indirect), not a disposal.

• Total holding now: 97,402,778 shares.

❓Why the Confusion?

• Form 605 is typically for reductions, not increases, so either:

  • There’s a filing mistake, or

  • They restructured their holdings in a way that removed them from being a “substantial holder” under technical legal definitions (e.g., through aggregation or separation of voting rights).

Summary

• No, it doesn't look like UniSuper paid Regal to short the stock.

• Rather, UniSuper increased their position in Botanix, likely via Regal, which now holds the shares on their behalf.

• There’s a possible administrative oddity in the choice of Form 605, but nothing indicates short-selling or intentional suppression followed by accumulation.

Let me know if you'd like to look up Regal’s latest filings or piece together more context.