Hi hone. What you said was very correct so I have done some research and I would appreciate anyone with knowledge of these things to help me out here. I could be very wrong.
ASIC says
Timing of disclosure under s671B
RG 222.45 Under s671B(1) of the Corporations Act, a person must give an initial
substantial holding notice to the listed entity and the market operator if they
have a relevant interest in 5% or more of the listed entity. The substantial
holder is then obliged to give a notice if there is a movement of 1% in its
substantial holding: s671B(2).
Note: A person’s substantial holding and any movements in that holding include the
relevant interests of the person’s associates, as defined in s12 of the Corporations Act.
See s9 (definition of substantial holding) and s671B(2).
RG 222.46 A substantial holder must give the notice to the listed entity and market
operator within two business days after becoming aware of the information
or by 9.30 am of the next business day during a takeover bid for the shares.
Consmin posted a substantial holding ann on the 02/06/2011
stating they had 22938000 shares they then posted another ann on the 08/02/2012 that they now hold 23640030 shares an increase of over 3%.
So Consmin have over 5% so have to post increases of over 1% within 2 business days but took 8 months? to disclose.
These shares were bought way before Henghou exercised. All before end of June last year.So dilution does not count
Hope I have not got this really wrong
Cheers steam
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