A Form 8937 might be required here though I really have no idea if this particular event will result in one. I see that the Form 8937 instructions also include this sentence: "You do not need to file Form 8937 for an initial public offering or an issuance of a debt instrument."
But if you've accurately described all the events surrounding this particular stock/ADS then the derivation of the basis of the ADS when you sell seems trivial. Since the ADS are trading on NASDAQ I'd think the company would have some sort of "Investor relations" department, so you should be able to ask them if a Form 8937 will be filed.
