This is an extract on the last ASX announcement"

"the Shares (45m) were issued at (0.01 cents) without disclosure to investors under Part 6D.2 of the
Corporations Act; = to fund raising of $450k.

Defining (or giving explanations on) above from Google are:

When can you raise funds without a disclosure document?

In certain circumstances, you may not need to comply with the requirement to provide a disclosure document when fundraising. It is important that you get legal advice about whether this could apply to you. A general summary of these circumstances is provided here. For more information see Regulatory Guide 254 Offering securities under a disclosure document (RG 254).

In summary, a disclosure document is not required when:

• an offer is a personal offer, and if:
  • offers or invitations have been made to fewer than 20 persons in the previous 12 months, and
  • the new offer will not result in more than $2 million being raised in that 12 months (see sections 708(1)–(7));
  Note: You must not advertise the offer when you rely on this exemption
• the offers are made to specified people who are presumed not to need disclosure because of their financial capacity, experience, association
  with the issuer or wholesale status (see sections 708(8)–(12));
• the offers are made to current holders of the securities (see sections 708(13)–(14A));
• no money or other form of payment is payable for the securities (see sections 708(15)–(16));
• other disclosure regimes under the Corporations Act apply (that is schemes of arrangement and takeovers) (see sections 708(17) and (18));
• the offers are made to creditors under a deed of company arrangement, if certain conditions are met (see section 708(17A));
• the offer of debentures is made by certain types of financial institutions (see section 708(19)).

In my opinion those shares were offered to the top 20 shareholders. Am I correct in thinkg this way?
If anyone can share their views (withot mocking around) I'd appreciate it, thanks.....