The section 249d to be approved requires more than 5% of combined shareholder value to be put forward. Not a single person owning 5%.
From what I can see on the top 20 / 40 this is what Michael Eliott holds, though he might hold more in another account, I do not believe he holds more than 3% of the company.
Based on that and the regulatory guide:
https://download.asic.gov.au/media/1236706/rg5-published-20-december-2013.pdf
Mike or his trust fund or his group he uses to directly buy stock, does not hold more than 5% of the company. So no disclosure of substantial holder needs to be made there.
What would a Global mining expert know?, page-7
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