Look at the announcment on 8th April.
In the table it says 'nature of change' - to which they responded 'Dilution via placement'.
It also says 'consideration' - 'N/A' as they didn't sell anything.
No. shares effected - 5m which takes them to 3.18% well under the 5% and hence why they aren't 'substantial'.
testing 4c. again, page-4
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