IPO - Emerald Clinics Limited, page-19

Convertible Note Offer
The Company has agreed to offer up to 20,625,000 Shares to third parties unrelated to the
Company (being the Noteholders (or their nominees)) on conversion of the Convertible Notes.
Details of the Convertible Notes are included in Section 7.7.
This Prospectus includes a separate offer of 20,625,000 Shares to the Noteholders (or their
nominees) (Convertible Note Offer). No Application Monies are payable under the Convertible
Note Offer.
The Company will not issue Shares under the Convertible Note Offer with the purpose of the
Noteholders (or their nominees) selling or transferring those Shares, or granting, issuing or
transferring interests in those Shares, within 12 months of the issue but this Prospectus provides
them the ability to do so should they wish.

With the convertible notes, does this mean they are or are not subject to 12 months escrow once converted to shares? Or does this prospectus allow them all to be converted into shares without escrow?