OSL 0.00% 1.2¢ oncosil medical ltd

I can see a number of "associates" whose pictures jointly appear...

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    I can see a number of "associates" whose pictures jointly appear together on a certain capital firm's website, and holding around 6% of shares together in various entities and SF accounts

    wondering if they should declare their holding with a sub holder notice ? are they associates as per RG5.2 below ?

    what do you think, folks ?

    https://download.asic.gov.au/media/5770142/rg5-published-27-august-2020.pdf

    https://hotcopper.com.au/data/attachments/5532/5532049-1fc662c6a529ecc53d754bfd4274847c.jpg

    https://hotcopper.com.au/data/attachments/5532/5532072-0f130b44a02f03e3bba04456c828ad48.jpg

 
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