Top20 shareholders, page-6

In most countries, the listed company will publish three lists as required under applicable securities law:

1. top twenty shareholders as appearing on the share register - this will typically include a lot of nominees who hold on behalf of their clients. The listed company does not reveal the underlying beneficial owners because unless #2 or #3 below applies, they do not have this information; and

2. list of substantial shareholders (in most countries I have looked at the threshold is 5% - not sure about Australia) who have filed the mandatory formal disclosure notices of their substantial shareholdings; and

3. list of holdings of directors and their affiliates based on mandatory formal disclosure notices filed by the directors.

Whenever there is a change under #2 or #3, an updated filing is required to be made to the company and the appropriate regulatory authority. Those filings are a matter of public record (disclosure notices appear all the time) and the register of filings should be available for public inspection. Changes to #1 do not require any notifications.

In all cases, the company files based on the information it receives - only in unusual circumstances would it do any processing of that information.

There will. of course, be overlap between the three lists.