RNS Number : 9027J

Citadel Group

02 December 2025

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FORM 8.3

IRISH TAKEOVER PANEL

OPENING POSITION DISCLOSURE/DEALING DISCLOSURE UNDER RULE 8.3 OF THE IRISH TAKEOVER PANEL ACT, 1997, TAKEOVER

RULES, 2022 BY PERSONS WITH INTERESTS IN RELEVANT SECURITIES REPRESENTING 1% OR MORE

1.             KEY INFORMATION

(a)   Full name of discloser	Citadel Group
(b)   Owner or controller of interests and short positions disclosed, if different from 1(a) The naming of nominee or vehicle companies is insufficient. For a trust, the trustee(s), settlor and beneficiaries must be named.	N/A
(c)   Name of offeror/offeree in relation to whose relevant securities this form relates Use a separate form for each offeror/offeree	AVADEL PHARMACEUTICALS PLC
(d)   If an exempt fund manager connected with an offeror/offeree, state this and specify identity of offeror/offeree (Note 1)	N/A
(e)   Date position held/dealing undertaken For an opening position disclosure, state the latest practicable date prior to the disclosure	1 December 2025
(f)    In addition to the company in 1(c) above, is the discloser also making disclosures in respect of any other party to the offer? If it is a cash offer or possible cash offer, state "N/A"	N/A

2.             INTERESTS AND SHORT POSITIONS

If there are interests and short positions to disclose in more than one class of relevant securities of the offeror or offeree named in 1(c), copy table 2 for each additional class of relevant security.

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Interests and short positions in the relevant securities of the offeror or offeree to which the disclosure relates following the dealing (if any)

(Note 2)

Class of relevant security (Note 3)	Common Stock ISIN IE00BDGMC594 $0.01 ordinary shares
	Interests		Short positions
	Number	%	Number	%
(1)   Relevant securities owned and/or controlled	972,622	0.99	317,885	0.32
(2)   Cash-settled derivatives	0	0.00	0	0.00
(3)   Stock-settled derivatives (including options) and agreements to purchase/ sell	162,400	0.16	783,000	0.80
Total	1,135,022	1.16	1,100,885	1.12

All interests and all short positions should be disclosed.

Details of options including rights to subscribe for new securities and any open stock-settled derivative positions (including traded options), or agreements to purchase or sell relevant securities, should be given on a Supplemental Form 8.

3.             DEALINGS (IF ANY) BY THE PERSON MAKING THE DISCLOSURE (Note 4)

Where there have been dealings in more than one class of relevant securities of the offeror or offeree named in 1(c), copy table 3(a), (b), (c) or (d) (as appropriate) for each additional class of relevant security dealt in.

The currency of all prices and other monetary amounts should be stated.

(a)           Purchases and sales

Class of relevant security	Purchase/sale	Number of securities	Price per unit (Note 5)
Common	Buy Transaction	775	21.3650 USD
Common	Buy Transaction	11	21.3700 USD
Common	Buy Transaction	16	21.3719 USD
Common	Buy Transaction	156	21.3732 USD
Common	Buy Transaction	6	21.3767 USD
Common	Buy Transaction	13	21.3831 USD
Common	Buy Transaction	1,590	21.3907 USD
Common	Buy Transaction	609	21.3923 USD
Common	Buy Transaction	22	21.3959 USD
Common	Buy Transaction	207	21.3971 USD
Common	Buy Transaction	7	21.4000 USD
Common	Buy Transaction	57	21.4037 USD
Common	Buy Transaction	1,191	21.4039 USD
Common	Buy Transaction	5	21.4040 USD
Common	Buy Transaction	71	21.4072 USD
Common	Buy Transaction	1,096	21.4079 USD
Common	Buy Transaction	475	21.4100 USD
Common	Buy Transaction	300	21.4101 USD
Common	Buy Transaction	68	21.4115 USD
Common	Buy Transaction	500	21.4120 USD
Common	Buy Transaction	73	21.4127 USD
Common	Buy Transaction	141	21.4131 USD
Common	Buy Transaction	389	21.4150 USD
Common	Buy Transaction	246	21.4151 USD
Common	Buy Transaction	61	21.4151 USD
Common	Buy Transaction	118	21.4152 USD
Common	Buy Transaction	1,548	21.4152 USD
Common	Buy Transaction	279	21.4156 USD
Common	Buy Transaction	1,665	21.4165 USD
Common	Buy Transaction	31	21.4168 USD
Common	Buy Transaction	1,979	21.4175 USD
Common	Buy Transaction	200	21.4175 USD
Common	Buy Transaction	2,646	21.4183 USD
Common	Buy Transaction	285	21.4185 USD
Common	Buy Transaction	4,211	21.4186 USD
Common	Buy Transaction	167	21.4187 USD
Common	Buy Transaction	1,346	21.4189 USD
Common	Buy Transaction	3,159	21.4197 USD
Common	Buy Transaction	806	21.4200 USD
Common	Buy Transaction	10,177	21.4200 USD
Common	Buy Transaction	1,600	21.4225 USD
Common	Buy Transaction	80	21.4250 USD
Common	Buy Transaction	2,866	21.4279 USD
Common	Buy Transaction	645	21.4334 USD
Common	Buy Transaction	1,142	21.4335 USD
Common	Buy Transaction	503	21.4365 USD
Common	Buy Transaction	250	21.4380 USD
Common	Buy Transaction	593	21.4390 USD
Common	Buy Transaction	1,245	21.4400 USD
Common	Buy Transaction	235	21.4404 USD
Common	Buy Transaction	50	21.4416 USD
Common	Buy Transaction	18	21.4433 USD
Common	Buy Transaction	630	21.4435 USD
Common	Buy Transaction	137	21.4436 USD
Common	Buy Transaction	2,029	21.4437 USD
Common	Buy Transaction	162	21.4438 USD
Common	Buy Transaction	5	21.4440 USD
Common	Buy Transaction	46	21.4450 USD
Common	Buy Transaction	2,966	21.4452 USD
Common	Buy Transaction	22	21.4455 USD
Common	Buy Transaction	3,220	21.4476 USD
Common	Buy Transaction	780	21.4491 USD
Common	Buy Transaction	566	21.4500 USD
Common	Buy Transaction	600	21.4501 USD
Common	Buy Transaction	187	21.4501 USD
Common	Buy Transaction	93	21.4501 USD
Common	Buy Transaction	88	21.4501 USD
Common	Buy Transaction	4,609	21.4527 USD
Common	Buy Transaction	303	21.4533 USD
Common	Buy Transaction	260	21.4535 USD
Common	Buy Transaction	32	21.4550 USD
Common	Buy Transaction	300	21.4551 USD
Common	Buy Transaction	68	21.4551 USD
Common	Buy Transaction	100	21.4600 USD
Common	Buy Transaction	435	21.4628 USD
Common	Buy Transaction	371	21.4646 USD
Common	Buy Transaction	1,730	21.4647 USD
Common	Buy Transaction	477	21.4666 USD
Common	Buy Transaction	3,897	21.4693 USD
Common	Buy Transaction	294	21.4700 USD
Common	Buy Transaction	580	21.4714 USD
Common	Buy Transaction	1,047	21.4714 USD
Common	Buy Transaction	200	21.4750 USD
Common	Buy Transaction	136	21.4882 USD
Common	Buy Transaction	150	21.4900 USD
Common	Buy Transaction	551	21.5000 USD
Common	Buy Transaction	739	21.5500 USD
Common	Buy Transaction	30	21.5600 USD
Common	Sell Transaction	258	21.3800 USD
Common	Sell Transaction	250	21.3900 USD
Common	Sell Transaction	3,012	21.3950 USD
Common	Sell Transaction	49	21.3951 USD
Common	Sell Transaction	131	21.3963 USD
Common	Sell Transaction	1,320	21.3995 USD
Common	Sell Transaction	84	21.4000 USD
Common	Sell Transaction	146	21.4026 USD
Common	Sell Transaction	32	21.4031 USD
Common	Sell Transaction	163	21.4057 USD
Common	Sell Transaction	44	21.4100 USD
Common	Sell Transaction	517	21.4117 USD
Common	Sell Transaction	1,013	21.4138 USD
Common	Sell Transaction	7,264	21.4150 USD
Common	Sell Transaction	1,495	21.4162 USD
Common	Sell Transaction	9	21.4167 USD
Common	Sell Transaction	390	21.4169 USD
Common	Sell Transaction	4,635	21.4170 USD
Common	Sell Transaction	110	21.4173 USD
Common	Sell Transaction	450	21.4180 USD
Common	Sell Transaction	604	21.4181 USD
Common	Sell Transaction	1,442	21.4185 USD
Common	Sell Transaction	7,620	21.4200 USD
Common	Sell Transaction	10,558	21.4210 USD
Common	Sell Transaction	384	21.4213 USD
Common	Sell Transaction	31	21.4216 USD
Common	Sell Transaction	4,312	21.4230 USD
Common	Sell Transaction	506	21.4233 USD
Common	Sell Transaction	227	21.4236 USD
Common	Sell Transaction	820	21.4245 USD
Common	Sell Transaction	589	21.4255 USD
Common	Sell Transaction	505	21.4260 USD
Common	Sell Transaction	11	21.4264 USD
Common	Sell Transaction	1,117	21.4300 USD
Common	Sell Transaction	576	21.4312 USD
Common	Sell Transaction	2,716	21.4335 USD
Common	Sell Transaction	2	21.4350 USD
Common	Sell Transaction	800	21.4375 USD
Common	Sell Transaction	153	21.4393 USD
Common	Sell Transaction	601	21.4400 USD
Common	Sell Transaction	130	21.4431 USD
Common	Sell Transaction	360	21.4441 USD
Common	Sell Transaction	404	21.4450 USD
Common	Sell Transaction	7	21.4471 USD
Common	Sell Transaction	644	21.4487 USD
Common	Sell Transaction	3,424	21.4500 USD
Common	Sell Transaction	132	21.4512 USD
Common	Sell Transaction	300	21.4517 USD
Common	Sell Transaction	573	21.4523 USD
Common	Sell Transaction	30	21.4550 USD
Common	Sell Transaction	1	21.4600 USD
Common	Sell Transaction	1,603	21.4601 USD
Common	Sell Transaction	18	21.4650 USD
Common	Sell Transaction	101	21.4700 USD
Common	Sell Transaction	66	21.5300 USD
Common	Sell Transaction	30	21.5600 USD

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(b)           Cash-settled derivative transactions

Class of
relevant
security Product
description
e.g. CFD Nature of dealing
e.g. opening/ closing a long/ short position, increasing/ reducing a long/ short position Number of
reference
securities
(Note 6) Price
per unit
(Note 5)

(c)           Stock-settled derivative transactions (including options)

(i)            Writing, selling, purchasing or varying

Class of relevant security	Product description e.g. call option	Writing, purchasing, selling, varying etc.	Number of securities to which option relates (Note 6)	Exercise price per unit	Type e.g. American, European etc.	Expiry date	Option money paid/ received per unit
Common	Call Option	Buy Transaction	200	10.0000 USD	American	2026-01-16	11.5000 USD
Common	Call Option	Sell Transaction	500	22.5000 USD	American	2025-12-19	0.0900 USD

(ii)           Exercise

Class of
relevant
security Product
description
e.g. call
option Exercising/
exercised
against Number of
securities Exercise
price per
unit
(Note 5)

(d)           Other dealings (including transactions in respect of new securities) (Note 3)

Class of
relevant
security Nature of dealing
e.g. subscription,
conversion, exercise Details Price per unit (if
applicable)
(Note 5)

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4.             OTHER INFORMATION

(a)           Indemnity and other dealing arrangements

Details of any indemnity or option arrangement, or any agreement or understanding, formal or informal, relating to relevant securities which may be an inducement to deal or refrain from dealing entered into by the person making the disclosure and any party to the offer or any person acting in concert with a party to the offer.

Irrevocable commitments and letters of intent should not be included. If there are no such agreements, arrangements or understandings, state "none"

 None

(b)           Agreements, arrangements or understandings relating to options or derivatives

Full details of any agreement, arrangement or understanding between the person disclosing and any other person relating to the voting rights of any relevant securities under any option referred to on this form or relating to the voting rights or future acquisition or disposal of any relevant securities to which any derivative referred to on this form is referenced. If none, this should be stated.

 None

(c)           Attachments

Is a Supplemental Form 8 attached? YES

Date of disclosure	2 December 2025
Contact name	Paula Santos
Telephone number	020 7645 9700

Public disclosures under Rule 8.3 of the Rules must be made to a Regulatory Information Service.

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SUPPLEMENTAL FORM 8

IRISH TAKEOVER PANEL

DISCLOSURE UNDER RULE 8.1, RULE 8.3, RULE 38.5(b) AND
RULE 38.6 OF THE IRISH TAKEOVER PANEL ACT, 1997,
TAKEOVER RULES, 2022

DETAILS OF OPEN STOCK-SETTLED DERIVATIVE (INCLUDING
OPTION) POSITIONS, AGREEMENTS TO PURCHASE OR SELL AND
RIGHTS TO SUBSCRIBE FOR NEW SECURITIES

1.             KEY INFORMATION

Full name of person making disclosure:	Citadel Group
Name of offeror/offeree in relation to whose relevant securities the disclosure relates:	AVADEL PHARMACEUTICALS PLC

2.             STOCK-SETTLED DERIVATIVES (INCLUDING OPTIONS)

Class of relevant security	Product description e.g. call option	Written or purchased	Number of securities to which option or derivative relates	Exercise price per unit	Type e.g. American, European etc.	Expiry date
Common	Call Option	Purchased	900	7.5 USD	American	19/12/2025
Common	Call Option	Purchased	24,200	22.5 USD	American	20/03/2026
Common	Put Option	Purchased	-3,100	12.5 USD	American	20/03/2026
Common	Put Option	Purchased	-100	20.0 USD	American	18/06/2026
Common	Call Option	Purchased	0	25.0 USD	American	20/03/2026
Common	Put Option	Purchased	-60,700	15.0 USD	American	16/01/2026
Common	Put Option	Purchased	-2,900	7.5 USD	American	19/12/2025
Common	Call Option	Purchased	5,600	12.5 USD	American	15/01/2027
Common	Put Option	Purchased	-44,400	10.0 USD	American	16/01/2026
Common	Put Option	Purchased	-3,800	15.0 USD	American	20/03/2026
Common	Put Option	Purchased	0	10.0 USD	American	20/03/2026
Common	Call Option	Purchased	5,100	15.0 USD	American	15/01/2027
Common	Call Option	Purchased	3,000	25.0 USD	American	15/01/2027
Common	Call Option	Purchased	0	5.0 USD	American	16/01/2026
Common	Call Option	Purchased	4,200	17.5 USD	American	16/01/2026
Common	Put Option	Purchased	-4,700	15.0 USD	American	19/12/2025
Common	Call Option	Purchased	100	22.5 USD	American	16/01/2026
Common	Put Option	Purchased	-1,000	17.5 USD	American	18/06/2026
Common	Put Option	Purchased	0	12.5 USD	American	15/01/2027
Common	Put Option	Purchased	-200	17.5 USD	American	20/03/2026
Common	Put Option	Purchased	-100	15.0 USD	American	15/01/2027
Common	Put Option	Purchased	-900	25.0 USD	American	20/03/2026
Common	Call Option	Purchased	5,800	22.5 USD	American	15/01/2027
Common	Put Option	Purchased	-100	7.5 USD	American	20/03/2026
Common	Call Option	Purchased	2,200	20.0 USD	American	18/06/2026
Common	Call Option	Sold	-183,000	10.0 USD	American	16/01/2026
Common	Call Option	Sold	-4,900	22.5 USD	American	19/12/2025
Common	Call Option	Sold	-65,900	12.5 USD	American	16/01/2026
Common	Call Option	Sold	-4,800	17.5 USD	American	15/01/2027
Common	Put Option	Sold	24,900	7.5 USD	American	16/01/2026
Common	Call Option	Sold	-13,500	10.0 USD	American	15/01/2027
Common	Call Option	Sold	-100	30.0 USD	American	19/12/2025
Common	Call Option	Sold	-30,000	15.0 USD	American	20/03/2026
Common	Call Option	Sold	-38,000	15.0 USD	American	19/12/2025
Common	Call Option	Sold	-6,200	12.5 USD	American	19/12/2025
Common	Call Option	Sold	-6,800	25.0 USD	American	19/12/2025
Common	Call Option	Sold	-5,400	20.0 USD	American	20/03/2026
Common	Call Option	Sold	-1,700	25.0 USD	American	16/01/2026
Common	Put Option	Sold	59,000	5.0 USD	American	16/01/2026
Common	Put Option	Sold	1,600	12.5 USD	American	19/12/2025
Common	Call Option	Sold	-9,600	7.5 USD	American	16/01/2026
Common	Call Option	Sold	-31,800	17.5 USD	American	19/12/2025
Common	Call Option	Sold	-46,200	20.0 USD	American	16/01/2026
Common	Put Option	Sold	2,000	17.5 USD	American	19/12/2025
Common	Put Option	Sold	8,200	10.0 USD	American	19/12/2025
Common	Call Option	Sold	-700	20.0 USD	American	19/12/2025
Common	Put Option	Sold	5,300	20.0 USD	American	19/12/2025
Common	Call Option	Sold	-10,200	7.5 USD	American	15/01/2027
Common	Call Option	Sold	-2,100	12.5 USD	American	20/03/2026
Common	Call Option	Sold	-10,000	17.5 USD	American	20/03/2026
Common	Call Option	Sold	-148,000	15.0 USD	American	16/01/2026
Common	Call Option	Sold	-100	35.0 USD	American	16/01/2026
Common	Put Option	Sold	5,500	12.5 USD	American	16/01/2026
Common	Call Option	Sold	-34,200	5.0 USD	American	15/01/2027
Common	Call Option	Sold	-2,600	30.0 USD	American	16/01/2026
Common	Put Option	Sold	4,400	17.5 USD	American	16/01/2026
Common	Call Option	Sold	-100	20.0 USD	American	15/01/2027
Common	Put Option	Sold	400	20.0 USD	American	20/03/2026
Common	Call Option	Sold	-5,100	10.0 USD	American	19/12/2025

3.             AGREEMENTS TO PURCHASE OR SELL

Full details should be given so that the nature of the interest or position can be fully understood:

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4.             RIGHTS TO SUBSCRIBE FOR NEW SECURITIES (INCLUDING DIRECTORS' AND OTHER EMPLOYEE OPTIONS)

Class of relevant security in relation to which subscription right exists:

Details, including nature of the rights concerned and relevant percentages:

It is not necessary to provide details on a Supplemental Form with regard to cash-settled derivatives.

The currency of all prices and other monetary amounts should be stated.

For full details of disclosure requirements, see Rule 8 of the Rules. If in doubt, consult the Panel.

References in these notes to "the Rules" are to the Irish Takeover Panel Act, 1997, Takeover Rules, 2022.

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