Ann: Cleansing Notice, page-2

I see in this Cleansing Notice they have placed some of the shortfall from last September's rights issue (RI). Here is the relevant part:

d. 10,000,000 ordinary shares at $0.03 and 10,000,000 primary options issued as placementout of shortfall of the entitlement offer as announced on 21 September 2018,

My understanding is that under the Corporations Act shortfall has to be placed within 3 months. Even in their prospectus released on the 17 Aug 2018 it says:

Placement OfferAny Shortfall Shares not subscribed for by Eligible Shareholders under the ShortfallOffer may be placed at the discretion of the Directors under section 708 of theCorporations Act . In order for any placement of the Shortfall Shares to be exemptfrom the application of ASX Listing Rule 7.1, Exception 3 to ASX Listing Rule 7.2requires that the Company must make any placement of the Shortfall Shares withinthree (3) months after the close of the Rights Issue Offer at an issue price that is notless than the Offer Price. The Directors of the Company, therefore, reserve the rightto issue any or all of the Shortfall Shares at their discretion on this basis.

So it seems to me they have done wrong ? ... as it's way more than 3 months since the rights issue closed. Either way, it's poor form to be issuing the shortfall now that the price (including the free options) is more than 200% higher than the rights issue price. Someone's in on the gravy train, and us who are not are being badly shifted it seems? If I'm right, I don't trust companies that do sneaky things like this. Maybe I'm wrong ... let me know if I've missed something.