So looking at it closer, it looks like they are clever in their...

So looking at it closer, it looks like they are clever in their timing. Looks like they waited until after their ASX SSH notice to sell.

But, this does not to my mind excuse the non-compliance with announcing the sale or the other dilution within 2 business days. They were surely well aware of the on-market sale and dilution.

To summarise the numbers from the SGX announcements on 19 August 2019:

30/05/2019: 93,388,728 (7.15%)
31/05/2019: 93,388,728 (6.55%, -0.6% due to GXY dilution)
26/07/2019: 87,908,228 (5.95%, -1.2% due to GXY+JBJLIL dilution and on-market sale)

Then on 12 July 2019 on the ASX they say:

24/07/2019: 93,388,728 (7.15%)
25/07/2019: 89,431,628 (6.057%)
Then on 26/07/2019 they sell shares on market.

And what a great day/week/something that was for A40 - when Burwill started selling down 5 to 6 million shares, and not telling the market.