Gerry Killen, a former senior executive in the group, is leading the challenge to Mr Lynch’s time as boss of the group and is demanding answers to several questions about the remuneration packages of Mr Lynch and others.
It is speculated that Mr Lynch’s overall pay deal is substantial.
In particular Mr Killen wants Mr Lynch to step aside as boss of the group while an independent investigator examines a patent royalty scheme understood to have paid out millions to the key executives in the group.
Mr Killen will seek to have chairman Denis Buckley and two other board members, Hugo Maguire and James Murphy, voted off the board.
He wants them replaced by himself; Alf Smiddy, the well-known former chief executive of Beamish & Crawford, and by former IBEC director Peter Brennan.
A significant core of minority shareholders wants full explanations for what has been going on and have submitted a list of detailed questions they want answered at tomorrow’s AGM which is scheduled for 11am at the Shelbourne Hotel in Dublin.
Last night a spokesman for One51 said the company will provide a “comprehensive response to the issues raised by a small group of shareholders in recent weeks”.
“The AGM is the appropriate occasion for the company to set out its position with regard to the future direction and strategy of the company.”
It is also understood that the board will back Lynch and the other executives for their handling of the business and in particular their handling of the environmental/waste business which Mr Lynch’s critics say has not been properly exploited.
They are also demanding that Mr Lynch sells off the minority stakes in NTR, Irish Continental Group and IFG, which they argue are ‘non-core’.
The group will also insist that everything has been done in line with best business practice.
Critics argue however, that Mr Lynch, who had a very impressive record as boss of IAWS, which he developed from the ashes of IAWS Co-op, has been severely damaged by the unfolding events.
In a further move, Mr Killen said that he will also query the accounts issued last week because they were unaudited.