It depends. I would encourage you to read the post that I sent you and you may decide if your shares fall within the guidelines of the test. My interpretation is that ADR's are stocks of foreign companies that trade in the U.S. markets are traded as American Depositary Receipts (ADRs). In looking at that third point, they might be qualified based on the language of the test.
I have no knowledge whether this is a universally accepted position. This is a decision that you would need to make. Here is a good reference source form the Securities and Exchange Commission that gives the deeper background and definition of ADR's. Between the two reference sources, you should have a good background on the subject.
@ThomasHansenDK
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