AGM Questions., page-4

Determining if a Corporation or Trustee of a trust is a foreign person
A corporation is considered to be a foreign person if:

• an individual not ordinarily resident in Australia, a foreign corporation or a foreign government holds a substantial interest in the corporation; or
• two or more persons, each of whom is an individual not ordinarily resident in Australia, a foreign corporation or a foreign government, hold an aggregate substantial interest.

When do two or more persons hold an aggregate substantial interest in a corporation or trust?
Two or more persons hold an aggregate substantial interest in a corporation if the persons, alone or with one or more associates, hold an aggregate interest of at least 40 per cent in the corporation (for example, voting or shares).

Hopefully they have done the correct due diligence and have made the right inquiries.