Yes, as long as there is a relationship, it has to be declared. If they don't and get caught out, ASIC would come down hard on them like a ton of bricks.
But, is ASIC going to look that hard??
It would be harder to detect if, whoever it is, and if it is related, to do it via a private entity that is registered in the British Virgin Island (BVI), where the name of the proprietors would be as hard as it can get, to find out as to who is working behind the scene.
It has happened before whereby even large investors in any company, are using an entity registered in the BVI's for that reason. There are a few companies that I know of that have large investors that are making use of that loophole.
Nevertheless, if ASIC will get a whiff of it in one way or another, there could be some big problems arising.
Hope this will help.
APG Price at posting:
3.9¢ Sentiment: Hold Disclosure: Held
