Ann: Top 20 Holders, page-4

1. "None of the Shares being offered for issue under the General Public Offer will be subject to ASX-imposed escrow. However, the Company expects that ASX will require certain Shares that are on issue prior to the Prospectus Date (and potentially, some Shares that will be issued under the Conversion Share Offer) to be classified as “Restricted Securities” meaning that any such Shares will be required to be held in “escrow” for up to 24 months from the date of Official Quotation."

Seems unusual for none of the founding shares to be subject to escrow.