Should ETFs be included in the definition of shares for the purposes of Article 12 of the Regulation?

Should Global Depository Receipts (GDR) and American Depository Receipts (ADR) be included in the definition of shares for the purposes of article 12 of the Regulation?

Is there a definition of the terms "position holder" and "reporting person", in order to establish for instance if the position holder is the fund, i.e. the legal entity which owns the short position, or the discretionary investment manager who makes the decision to take the short position.

Would the issuance of a Credit Linked Note be subject to the duration adjustment or to the delta adjustment?

For the purpose of calculating the net short position in the sovereign debt of a sovereign issuer, is a duration adjustment required to be applied to derivative positions referenced in that sovereign debt?