This is very strange as this holding company has never appeared...

This is very strange as this holding company has never appeared on the substantial holders list:
http://www.pel.net.au/images/peninsul---ielenaezoh.pdf 31st January 2019

http://www.pel.net.au/images/peninsul---vaangeixah.pdf 31st December 2018

Also the 14 million share volumes sold on the "Open Market" do not represent the volumes being sold around that time.  This must have been a block sale.

Looking at the individual holders, could this be a holdings company positioning themselves against possible s232 implications?

Seems quite a mystery with all the progress and potential milestones around the corner.

What is encouraging is despite this holding company and URA bailing out the share price has rallied