Ah, ok. The equivalent in Australia is a CHESS Depositary Interest ( CDI ):
http://www.asx.com.au/documents/settlement/CHESS_Depositary_Interests.pdf
The important part is the part that says "without actually holding legal title to those financial products"
So I presume an ADR is the same ( e.g. not holding legal title ), so therefore does not appear in the ASX's substantial holder list.
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Ah, ok. The equivalent in Australia is a CHESS Depositary...
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