One final point is that there is another rule known as the cash formula for investors that have invested in the the previous 12 months pre IPO/RTO. Part of their shares are escrowed, i.e. the uplift/profit component.
An example is as follows; investor invests 100k at 5c pre IPO and the IPO is at 10c. Half the stock (100k worth at 10c) is escrowed for a period up to 12 months from the date of investment. The other 100k is tradeable.
This protects the IPO/RTO incoming shareholders.
So, in summary, maybe they are all less than 10% and have held the stock for more than 12 months. It would have all been in the prospectus.
Where's ASIC?!!!, page-35
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