It is not a dilution of that scale, as it replaces 4m free shares with 15million 12c shares that will only be taken up if the share price is over $0.12 (or over 16c for some of them). If the price at vesting is under 12c nobody will take up the offer, so no dilution.
So I think it is a substantially better deal for shareholders than the original 4m shares.
in any case, it suggests the CEO is extremely confident the share price will be over 16c within 3yrs.
Ann: Executives incentivised through securities issue, page-4
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