Tan, you're right to ask how I know whether some of the top shareholders have united. In a public forum like this, there are limits to how much detail can be shared. Some conversations are confidential, and some coordination efforts are still unfolding behind the scenes. However, based on observable signs and reasonable inferences, it's fair to conclude that some level of coordination among key holders has already begun—especially among those whose investments have been severely devalued by recent events.
Look at the top holders like JEY Investment, Mahe Investments, Rockharp, Umbiram, and others. These are not passive investors. Many of them now hold positions that are deeply underwater following the highly dilutive 0.3 cent rights issue. Take Mahe, for example. While Mahe may have received fees from the company, they also have a large financial position that has lost significant value. It's unlikely that institutions with this much capital at stake are content to sit idle while their investments are reduced to near zero. You can view the full list of top 40 shareholders here:
https://www.biotron.com.au/wp-content/uploads/2024/10/Top-40-Holders-Report-28-April-2025.pdf
Rather than debating whether unity already exists, the priority now is to push for it to happen. If you know any of these holders, or have access through networks, now is the time to encourage them to connect. Whether you're a large investor or a retail shareholder, coordination is the only path forward. Too much value has been lost through inaction and mismanagement—and it will continue unless shareholders act together.
The recent capital raise at 0.3 cents per share was not just unfortunate timing—it was a reckless and unnecessary decision. Management had a clear window to raise funds when the share price was over 8 to 9 cents. Many shareholders would have gladly supported a capital raise at those levels and exercised their options. Instead, the board delayed action until the company was in financial distress, and then accepted terms that severely diluted existing shareholders. This decision alone demands serious scrutiny.
Meanwhile, the capital raised is being consumed mostly by executive salaries and ongoing payments to a purpose-server-service-provider C14, that after several months, has delivered no commercial outcome. BTW, where are the final results analyses from the CROs? How is C14 working without final results analyses from CROs? Did the Biotron management update anyhting on the final results analysises? Ans is No, not yet! But why? If the planned $2.7 million or so is not fully raised, management is likely to use it as a justification to seek more capital—or worse, push the company into voluntary administration. It’s a destructive cycle, and the pattern raises serious concerns about whether these failures are accidental—or deliberate.
The company continues to operate behind a wall of silence, using “commercial in confidence” as a blanket excuse to avoid transparency. But after 24 years of promises and zero deals, that excuse is no longer credible. Shareholders did not fund Biotron for it to become a black hole of accountability—they invested in the promise of scientific progress and commercial results. Instead, they have been met with silence, dilution, and eroded value.
The first and most impactful collective action shareholders can take right now is to individually and repeatedly file complaints to ASIC. Each submission should be backed with evidence pulled from Biotron’s ASX announcements, shareholder webinars, annual reports, and its capital raising history. The goal is simple: overwhelm ASIC with consistent, well-documented complaints so they are forced to pay attention and investigate. One complaint may be ignored. Dozens or hundreds will not.
Holders can submit complaints here:
https://asic.gov.au/about-asic/contact-us/how-to-complain/ (follow the steps, draft your complanints and imporve the writing claritya dn specificity and stronger with reference to the evidence and keep submitting)
In parallel, shareholders holding 5% or more of the company’s voting shares have the legal right to requisition an Extraordinary General Meeting (EGM). This can be used to:
Remove or appoint directors,
Demand full disclosure of the C14 arrangement,
Investigate the decisions behind the 0.3c capital raise, and
Mandate clear, time-bound commercialization milestones.
If these measures are not taken, shareholders should strongly consider a class action to pursue accountability for what may be breaches of fiduciary duty, misleading conduct, and failure to act in shareholders’ best interests.
Let’s be clear: ASIC may overlook ordinary poor performance. But this is not that. This appears to be systematic poor performance, orchestrated and disguised to erode shareholder value, while shielding executives from consequences. That’s not mismanagement—that is potential corporate misconduct and financial abuse.
The CEO, Chairman, and any director involved in this silence and inaction must be held personally accountable. They had the opportunity—and arguably, the obligation—to raise funds responsibly when the share price was much higher. Instead, they stayed silent, allowed the company’s position to deteriorate, and then approved a capital raise at 0.3c—a move that devastated existing shareholders.
This cannot be brushed aside. ASIC must investigate this as a potential case of financial misconduct and shareholder deception. Executives who knowingly led the company down this path should face serious regulatory consequences—including multi-million-dollar fines, disqualification from corporate roles, and formal sanctions for breaching their duties.
This situation affects more than just Biotron—it undermines trust in Australia’s listed markets. If ASIC fails to act, it sets a dangerous precedent for other boards to behave the same way. That’s why the response must be strong, swift, and collective.
Biotron is not beyond saving. But saving it depends on whether shareholders stand up now, speak with one voice, and demand action. It starts with complaints to ASIC. It continues with pressure on the board. And if necessary, it ends with legal action.
(20min delay)