One final point is that there is another rule known as the cash...

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.