Ann: Becoming a substantial holder, page-9

Perhaps, but not necessarily. It depends on what the thesis demonstrates. In any event, insiders buying up usually comes within a hair's breadth of being considered something else. In TSF's case, however, seems to have been about for a while but has only gone active since 22/9/17 (and especially in the period through to 8/11/17) which was up to when the most recent T20 list was compiled.

First appeared in the T20 in AR16 with 1.5M shares. Stayed unchanged at this through AR17 (up to 22/9/17). Has only bought since then. Now has 12.1M shares. Became a substantial shareholder on 15/1/18. In the 4 months prior to this, TSF had acquired ~4M shares. In the 6 weeks however following AR17, acquired 6.6M shares, so quite active in the lead up to AGM17.

At 22/9/17, TSF held 1.5M shares and since 9/11/17, has acquired a further 4M shares. Between 25/9/17 and 8/11/17 however, TSF acquired ~6.6M shares out of 10.7M (ASX) traded in that time including the 3.038M that were traded on 8/11/17 (>60% of ASX traded shares). Excluding this however, as the SSN is somewhat difficult to read (ie: as to whether the earliest notified trade was from 8/11 or 9/11), then it would have been 6.6M shares out of 7.7M traded (>80% of the ASX traded shares). In the last few months, the ASX trading has virtually been a market of one, 2 or 3 depending on whether you also include the Hackett and Skene purchases, but not much else.

On 8/11/17, the Camperdown Dairy Park land announcement was made which precipitated the 3M+ share trading activity of that day followed by a further million plus trading day on the 9th. Otherwise, trading then retired to its old, sedentary pace.

So, perhaps knows something, but more likely than not, bought in between AR15 and AR16, so therefore at a much higher SP than now prevails. The average SP between AR15 and AR16 was 22c and between 1/12/15 - 22/9/16 (a month before the CDC announcement), was 22.5c. The average original investment was therefore likely at upwards of $330,000 (minimum) using a 22c SP average.

The SP average since 25/9/17 (through 15/1/18) has been ~12c (= 11.8c ave) whilst TSF has bought ~10.6M shares ($ ave = $1.250M).

Total invested effort therefore is likely to have been upwards of $1.58M to date. Perhaps, as high as $1.6M, for an overall pricing average of 13.06c - 13.22c.

The co-incidence therefore is in someone else now buying /trying to buy and putting in place for themselves an SP starting average of circa 13.5c (shades of Moran, perhaps).

The potential insider connection arises because the TSF is Brisbane bound with an East Brisbane ABN address residential unit and there is a similar named person who, according to LinkedIn is a Brisbane based accountant. But these are all co-incidences. As for being an insider, the actions /behaviour (or absence thereof before AR16) suggests not, but the possibility of FOMO or of NETOMO (need to match others in their starting price) suggests what might otherwise be happening here. Then, again, the bulk of the shares were bought in the period leading up to AGM17 whilst the ongoing purchasing since then has tapered off. So, not likely as an insider, but perhaps friendly to both BOD/BOM. Time however will soon tell, especially now with another GM rising.