Someone posted the DOCA files from Kordamentha a while back. Took me ages to find them again...
Looks to me like the majority of "Transfer shares" would have been held briefly by the trust...
You'll find the full doc for anyone better equipped than I to wade through the DOCA here:
http://www.kordamentha.com/docs/def...ela/140513---mirabela-nickel-limited-doca.pdf
