The Panel, Richard Hunt (sitting President), John Sheahan QC and Jane Sheridan, made a declaration of unacceptable circumstances in relation to the affairs of Northern Iron Limited. The application concerned non-compliance with substantial holder notice and tracing notice provisions. The Panel considered that the non-disclosure resulted in shareholders, the directors and the market not knowing the identity of a person who was proposing to acquire, and had acquired, a substantial interest. The Panel ordered disclosure, a ‘creep’ freeze and costs.