Section 671B of the Corporations Act 2001 requires a substantial...

Section 671B of the Corporations Act 2001 requires a substantial shareholder to disclose a change of 1%.

Burwill's two SSH notices dated 19 August 2019 on the SGX relate to events on 31 May 2019 (dilution) and 26 July 2019 (on-market sale).

In both matters, they say they were unaware until 7 August 2019 of events leading to a reduction in their voting/holding capacity from 7.15% to 5.59%.

Interestingly, Burwill did not disclose a further sale of approximately 2 million shares in its ASX SSH notice dated 8 August 2019: https://www.asx.com.au/asxpdf/20190812/pdf/447d48gmdgrlrk.pdf

In any event, an ASX SSH notice is meant to be disclosed within 2 business days of becoming aware of the change.

Given that under s 671B it is a criminal offence (and gives rise to civil liability for losses caused by a breach) to contravene the requirements, I wonder why Burwill magically did not know it had between 31 May and 26 July gone down 1%, and why there's a difference between the disclosed number of shares held despite relating to the same transactions?