I'm in a similar situation, but my understanding is any person, or associated entity, who participated placement or SPP is ineligible.
Any person who participated in the Placement or any associate of that person, and any other person who is expected to obtain a material benefit as a result of the issue of New Options (except a benefit solely by reason of being a holder of Shares), and any of their associates.
Otherwise what's the point of the rule?
Most large participants will have more than one entity holding shares.
Ann: Industry presentation - AABC Europe 2024, page-127
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