I know what you're thinking is but it can't be. Any buying by associated or related entities would need to be disclosed otherwise they are in deep do do with ASIC. From here on in they will need to lodge Form 604's with every 1% increase. That's not to say they couldn't buy another large chunk in one big hit & then lodge the form - up to 19.9%.
Maybe it was strategic to get better knowledge of SIM, so wouldn't be surprised to see a Mega associated director being elected to the board.
SIM Price at posting:
0.0¢ Sentiment: ST Buy Disclosure: Held