The insider reporting requirement does not apply to a reporting insider if the reporting insider
(a) does not have any beneficial ownership of, or control or direction over, whether direct or indirect, a security of the issuer;
(b) does not have any interest in, or right or obligation associated with, a related financial instrument involving a security of the issuer;
(c) has not entered into any agreement, arrangement or understanding as described in section 4.1; and
(d) is not a significant shareholder based on post-conversion beneficial ownership.