The description of the document clearly states who has to file this (hint: it is not SIAF):
"Schedule filed to report acquisition of beneficial ownership of 5% or more of a class of equity securities by passive investors and certain institutions"
On page 1 you can see the date of the event (December 31, 2015). This all means that Incentive ownership has no connection to the listing at Merkur Market and that all Incentive shares has been bought on OTC Market....
What is possible though is that Incentive started to accumulate shares after the announcement to list on OSE and that they have been adding during all 2015.
Since we have information from January 29 of the big owners on Merkur, Incentive did not convert their shares to SIAF-ME up until last week anyways.
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