Isn't it possible though that individual stake holders can be...

Isn't it possible though that individual stake holders can be accumulating via more than one account holding or behind a nominee account and/or trading the stock until such time as they want to hold more shares? There are ways and means of accumulating and yet avoiding having to lodge a Form 604 I should imagine - by simply staying below the threshold required before disclosure is required.

My understanding is that a person must provide substantial holding notice relating to movements above or below the 5% substantial holding threshold - after which threshold, and any change of 1% or more requires declaration.

As at the date of the last notice provided in the Annual Report, even the Top SH, David Kenley, would need to more than double the number of shares he holds before requiring to lodge a change of substantial shareholder notice. In other words, accumulation can be going on by a mnumber of the Top 20 stakeholders without any disclosure being required. Well, correct me if that understanding is incorrect, please, because I am far from full bottle on this stuff.