Yes, I would report stocks purchased through an American Depository Receipt (ADR) as foreign assets for 8938 if you meet the reporting thresholds. This is because the ADR acts as an exchange and you purchase the stocks directly through the ADR, as opposed to other asset holding companies who essentially hold the assets and you invest in the fractional shares (and thus the holding company reports the assets).
In general, with the foreign reporting, I would err on the side of caution and report (because you are not actually paying any tax on the assets) and the penalties for not reporting are quite punitive, but that is just my opinion.