Next time you speak with MHTX, you might tell them that ASIC and ASX reporting rules require a substantial holder, i.e. a holder with more than 5% of a publicly listed company on the ASX to report any change of 1% or more IRRESPECTIVE OF WHETHER IT'S DUE TO THEIR OWN TRANSACTIONS OR TO TRANSACTIONS BY OTHER HOLDERS e.g. due to dilution by placements and CRs in which MHTX didn't participate.
The relevant form is called 604 Notice of Change of Interest of Substantial Holder. It should be sent by the holder to the IBX Company Secretary, who then forwards it to the ASX for an official announcement.
The ASIC Guidance Note is attached. ASIC RG5 Substantial Holding Notices.pdf . (Also, if the substantial holder falls below 5%, they have to send a Form 605 Ceasing Substantial Holding.)
I doubt anyone is going to end up in jail over the omission to send the Form 604s each time there was a placement or rights issue where MHTX didn't participate, but I think it's safer to follow the official procedures.
