Shagang's direct holding of 540.2mil shares probably hasn't changed since it last reported on 29Mar18 for shares held on 25Jan18 but its associate RGL Holdings that reported a shareholding of 24.8mil shares on 25Jan18 has probably sold out completely. We know for sure that they had reduced their holding to 19.7mil by 21Mar18(as per the listing in the Annual Report).
So yes Shagang should report the sale by RGL Holdings as that entity had more than 2% of issued shares on 25Jan18 although if my presumption of RGL Holdings selling out is incorrect and they still had 19.7mil shares then Shagang would not have to report as less than half a per cent had been sold between 25Jan18 and 21Mar18.
Ann: Change in substantial holding, page-18
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