Ann: Market Update, page-118

Sorry mate was on holidays but yes you're correct. They cannot issue themselves shares out of the capital raise bucket without paying.

They can, however, issue themselves performance shares, or options, or if they owned shares in one of the ventures they are purchasing, issue shares to themselves that way, so long as shareholders have approved the transactions.

Performance shares/options normally get approved at the AGM under the remuneration report approval. Other shares given via transaction etc have to be approved at the same time as the transaction, normally under the same vote.

I also couldn't actually find in the latest prospectus where it says they are putting in for 3.8million shares, only that they wish to participate (as per section 6.9). If they put in for any shares in the capital raising, it will come from their own money.