Ann: Loyalty Options Prospectus, page-10

Questions from ignorance ...
1/ today the company issued an Appendix 3G which advised 80,700,000 Loyalty Options being issued. At 1 for 15 this equates to 1.21bn shares which lines up with the total shares on issue. But aren't some of these shares representing the ADR's that are on the Nasdaq?
2/ The prospectus says the loyalty options aren't offered to US residents - so do ADR holders get loyalty options?
3/ The Appendix 3G doesn't identify any escrowed positions - I recall some old 3B's (or maybe 3G's) showing escrowed holdings - is this no longer required?
4/ Are any of the director's positions escrowed - thought some had been locked up for the Nasdaq listing?
4/ Around 6 months ago, Dr Sud had lots of $0.20 cent options when the share price was $0.35 - before expiry he exercised nearly 21m for an investment of $4.2m (wow!). Not having a go at him because he holds an enormous position showing amazing commitment to IHL, but this time he holds an entitlement for another 7,150,000 loyalty options that will need another $2.5m to exercise - is there any statement in the prospectus that shows his intent - he will stand to make a further pretty penny if the price holds at these levels but I couldn't find anything about whether or not he will be exercising.