Ann: Change in substantial holding, page-10

I have had a close look at the Australian Super's holdings and subsequently created a spreadsheet indicating the % of their holdings relative to the total number of shares on issue from 31/3/2017 until last week. At no time was their shareholding less than 5%. It was my understanding that each change in the total number of shares owned by a substantial shareholder was required to be notified to the ASX.

As there has been no notifications of change of substantial holding during that time period by Australian Super, I can only conclude that some broker was accumulating shares, perhaps on behalf of Australian Super. It would appear that even though that broker may have held shares on behalf of Nominees to such an extent that those shares totalled more that 5% of total shares on issue by CLQ, they in themselves were not required to disclose changes in the number of shares held by them for Nominees. It would be appreciated if someone could confirm whether that is the case.

The disclosure of the increase in the number of shares held by Australian Super as per the ASX Announcement on 10/8/18 seems to indicate that the additional shares which were the subject to the Notice, started being accumulated from the 11/8/2017, and continued being accumulated from then, when the price was 76c, right up till the price was $1.72 and back down again to 67c. There was no month during that period when shares weren't being purchased.

I am wondering whether the S3 XT trade that was made on the 8/8/18 of 17,328,054 shares is in some way connected to the change in holding of 18,119,871 shares representing the increased holding by Australian Super on 7/8/18. Perhaps some broker was accumulating for Australian Super, and lending the shares for "shorting" purposes to some other third party? If that was the case, it would be a win win for Australian Super as they would be accumulating whilst the share price was being manipulated down by the shorters.

Thoughts?