I haven't done the maths, but if that sale of 40,000,000 altered their percentage of shares held by less than 1% they do not have to give a change in substantial holding notice.
Actually even with rough maths there is no way that 40,000,000 shares is less than a 1% movement. Bit odd.
My understanding is that the onus here is solely on the shareholder and does not reflect back on the company.
