RNS Number : 1893L

Citadel Group

11 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	10 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	980,699	0.99	245,168	0.24
(2)   Cash-settled derivatives	0	0.00	0	0.00
(3)   Stock-settled derivatives (including options) and agreements to purchase/ sell	240,200	0.24	795,600	0.81
Total	1,220,899	1.24	1,040,768	1.06

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	1	21.3700 USD
Common	Buy Transaction	132	21.3800 USD
Common	Buy Transaction	100	21.3850 USD
Common	Buy Transaction	224	21.3851 USD
Common	Buy Transaction	344	21.3868 USD
Common	Buy Transaction	1,280	21.3891 USD
Common	Buy Transaction	24	21.3896 USD
Common	Buy Transaction	6,670	21.3898 USD
Common	Buy Transaction	2,246	21.3900 USD
Common	Buy Transaction	908	21.3911 USD
Common	Buy Transaction	7	21.3929 USD
Common	Buy Transaction	2,394	21.4000 USD
Common	Buy Transaction	601	21.4001 USD
Common	Buy Transaction	750	21.4001 USD
Common	Buy Transaction	203	21.4002 USD
Common	Buy Transaction	1,315	21.4015 USD
Common	Buy Transaction	69	21.4033 USD
Common	Buy Transaction	5	21.4060 USD
Common	Buy Transaction	13	21.4069 USD
Common	Buy Transaction	3,576	21.4100 USD
Common	Buy Transaction	2,769	21.4100 USD
Common	Buy Transaction	273	21.4114 USD
Common	Buy Transaction	564	21.4116 USD
Common	Buy Transaction	86	21.4116 USD
Common	Buy Transaction	1,239	21.4142 USD
Common	Buy Transaction	401	21.4149 USD
Common	Buy Transaction	342	21.4150 USD
Common	Buy Transaction	6,793	21.4150 USD
Common	Buy Transaction	825	21.4152 USD
Common	Buy Transaction	7,000	21.4157 USD
Common	Buy Transaction	4,443	21.4159 USD
Common	Buy Transaction	6,607	21.4167 USD
Common	Buy Transaction	515	21.4175 USD
Common	Buy Transaction	2,320	21.4178 USD
Common	Buy Transaction	310	21.4200 USD
Common	Buy Transaction	800	21.4201 USD
Common	Buy Transaction	10,619	21.4206 USD
Common	Buy Transaction	1,500	21.4210 USD
Common	Buy Transaction	219	21.4231 USD
Common	Buy Transaction	1,700	21.4256 USD
Common	Buy Transaction	392	21.4264 USD
Common	Buy Transaction	587	21.4265 USD
Common	Buy Transaction	1,166	21.4272 USD
Common	Buy Transaction	1,062	21.4275 USD
Common	Buy Transaction	432	21.4285 USD
Common	Buy Transaction	1,060	21.4292 USD
Common	Buy Transaction	3,300	21.4300 USD
Common	Buy Transaction	1,229	21.4328 USD
Common	Buy Transaction	1,540	21.4344 USD
Common	Buy Transaction	200	21.4350 USD
Common	Buy Transaction	1,200	21.4358 USD
Common	Buy Transaction	2	21.4400 USD
Common	Buy Transaction	200	21.4450 USD
Common	Buy Transaction	300	21.4500 USD
Common	Buy Transaction	394	21.4502 USD
Common	Buy Transaction	3	21.4533 USD
Common	Buy Transaction	606	21.4550 USD
Common	Buy Transaction	1,031	21.4576 USD
Common	Buy Transaction	200	21.4600 USD
Common	Buy Transaction	252	21.4681 USD
Common	Buy Transaction	201	21.4700 USD
Common	Buy Transaction	670	21.4776 USD
Common	Buy Transaction	1,217	21.4800 USD
Common	Buy Transaction	3	21.4867 USD
Common	Buy Transaction	330	21.5000 USD
Common	Buy Transaction	324	21.5090 USD
Common	Sell Transaction	2	21.3700 USD
Common	Sell Transaction	9,065	21.3894 USD
Common	Sell Transaction	2,318	21.3900 USD
Common	Sell Transaction	1,364	21.3933 USD
Common	Sell Transaction	694	21.3933 USD
Common	Sell Transaction	110	21.3950 USD
Common	Sell Transaction	35	21.3980 USD
Common	Sell Transaction	801	21.4000 USD
Common	Sell Transaction	26	21.4012 USD
Common	Sell Transaction	902	21.4023 USD
Common	Sell Transaction	300	21.4050 USD
Common	Sell Transaction	26	21.4062 USD
Common	Sell Transaction	594	21.4064 USD
Common	Sell Transaction	541	21.4078 USD
Common	Sell Transaction	4,200	21.4079 USD
Common	Sell Transaction	524	21.4085 USD
Common	Sell Transaction	1,496	21.4100 USD
Common	Sell Transaction	2,400	21.4117 USD
Common	Sell Transaction	782	21.4128 USD
Common	Sell Transaction	755	21.4148 USD
Common	Sell Transaction	330	21.4150 USD
Common	Sell Transaction	63	21.4154 USD
Common	Sell Transaction	38	21.4155 USD
Common	Sell Transaction	7,000	21.4157 USD
Common	Sell Transaction	7,700	21.4160 USD
Common	Sell Transaction	600	21.4167 USD
Common	Sell Transaction	540	21.4168 USD
Common	Sell Transaction	1,898	21.4175 USD
Common	Sell Transaction	1,856	21.4180 USD
Common	Sell Transaction	2,294	21.4181 USD
Common	Sell Transaction	1,222	21.4183 USD
Common	Sell Transaction	279	21.4196 USD
Common	Sell Transaction	5,896	21.4200 USD
Common	Sell Transaction	679	21.4206 USD
Common	Sell Transaction	305	21.4206 USD
Common	Sell Transaction	904	21.4218 USD
Common	Sell Transaction	133	21.4234 USD
Common	Sell Transaction	2,503	21.4235 USD
Common	Sell Transaction	490	21.4250 USD
Common	Sell Transaction	358	21.4250 USD
Common	Sell Transaction	1,610	21.4258 USD
Common	Sell Transaction	225	21.4278 USD
Common	Sell Transaction	161	21.4300 USD
Common	Sell Transaction	506	21.4301 USD
Common	Sell Transaction	230	21.4304 USD
Common	Sell Transaction	100	21.4350 USD
Common	Sell Transaction	1,410	21.4352 USD
Common	Sell Transaction	298	21.4354 USD
Common	Sell Transaction	460	21.4365 USD
Common	Sell Transaction	2,961	21.4386 USD
Common	Sell Transaction	365	21.4390 USD
Common	Sell Transaction	791	21.4397 USD
Common	Sell Transaction	2	21.4400 USD
Common	Sell Transaction	149	21.4432 USD
Common	Sell Transaction	306	21.4448 USD
Common	Sell Transaction	1,100	21.4450 USD
Common	Sell Transaction	684	21.4494 USD
Common	Sell Transaction	501	21.4500 USD
Common	Sell Transaction	358	21.4508 USD
Common	Sell Transaction	84	21.4614 USD
Common	Sell Transaction	323	21.4619 USD
Common	Sell Transaction	100	21.4650 USD
Common	Sell Transaction	41	21.4690 USD
Common	Sell Transaction	514	21.4700 USD
Common	Sell Transaction	378	21.4746 USD
Common	Sell Transaction	12	21.4783 USD
Common	Sell Transaction	4,628	21.4800 USD
Common	Sell Transaction	8	21.4850 USD
Common	Sell Transaction	19	21.5153 USD
Common	Sell Transaction	9	21.5156 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	16,000	20.0000 USD	American	2025-12-19	1.4000 USD
Common	Call Option	Buy Transaction	2,000	20.0000 USD	American	2025-12-19	1.4400 USD
Common	Call Option	Sell Transaction	1,000	25.0000 USD	American	2027-01-15	0.0900 USD
Common	Call Option	Sell Transaction	2,000	25.0000 USD	American	2027-01-15	0.1000 USD
Common	Call Option	Sell Transaction	500	22.5000 USD	American	2026-03-20	0.1500 USD
Common	Call Option	Sell Transaction	100	20.0000 USD	American	2026-03-20	1.4500 USD
Common	Call Option	Sell Transaction	1,000	20.0000 USD	American	2026-03-20	1.5300 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	11 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	Put Option	Purchased	-100	20.0 USD	American	18/06/2026
Common	Put Option	Purchased	-44,400	10.0 USD	American	16/01/2026
Common	Call Option	Purchased	5,600	12.5 USD	American	15/01/2027
Common	Put Option	Purchased	-900	25.0 USD	American	20/03/2026
Common	Call Option	Purchased	900	7.5 USD	American	19/12/2025
Common	Put Option	Purchased	-3,800	15.0 USD	American	20/03/2026
Common	Call Option	Purchased	0	5.0 USD	American	16/01/2026
Common	Put Option	Purchased	-4,700	15.0 USD	American	19/12/2025
Common	Put Option	Purchased	-100	7.5 USD	American	20/03/2026
Common	Call Option	Purchased	5,100	15.0 USD	American	15/01/2027
Common	Put Option	Purchased	0	12.5 USD	American	15/01/2027
Common	Call Option	Purchased	5,100	22.5 USD	American	15/01/2027
Common	Put Option	Purchased	-200	17.5 USD	American	20/03/2026
Common	Call Option	Purchased	23,700	22.5 USD	American	20/03/2026
Common	Put Option	Purchased	-1,000	17.5 USD	American	18/06/2026
Common	Put Option	Purchased	-2,900	7.5 USD	American	19/12/2025
Common	Put Option	Purchased	-100	15.0 USD	American	15/01/2027
Common	Call Option	Purchased	4,200	17.5 USD	American	16/01/2026
Common	Put Option	Purchased	0	10.0 USD	American	20/03/2026
Common	Put Option	Purchased	-3,100	12.5 USD	American	20/03/2026
Common	Call Option	Purchased	59,800	20.0 USD	American	19/12/2025
Common	Put Option	Purchased	-60,700	15.0 USD	American	16/01/2026
Common	Call Option	Purchased	0	25.0 USD	American	15/01/2027
Common	Call Option	Purchased	0	25.0 USD	American	20/03/2026
Common	Call Option	Purchased	2,200	20.0 USD	American	18/06/2026
Common	Call Option	Sold	-4,900	22.5 USD	American	19/12/2025
Common	Put Option	Sold	300	20.0 USD	American	20/03/2026
Common	Put Option	Sold	5,500	12.5 USD	American	16/01/2026
Common	Call Option	Sold	-6,500	20.0 USD	American	20/03/2026
Common	Call Option	Sold	-2,600	30.0 USD	American	16/01/2026
Common	Put Option	Sold	59,000	5.0 USD	American	16/01/2026
Common	Call Option	Sold	-10,000	17.5 USD	American	20/03/2026
Common	Call Option	Sold	-38,000	15.0 USD	American	19/12/2025
Common	Call Option	Sold	-100	20.0 USD	American	15/01/2027
Common	Call Option	Sold	-29,900	22.5 USD	American	16/01/2026
Common	Call Option	Sold	-2,100	12.5 USD	American	20/03/2026
Common	Call Option	Sold	-65,900	12.5 USD	American	16/01/2026
Common	Put Option	Sold	8,200	10.0 USD	American	19/12/2025
Common	Put Option	Sold	1,600	12.5 USD	American	19/12/2025
Common	Call Option	Sold	-46,200	20.0 USD	American	16/01/2026
Common	Call Option	Sold	-4,800	17.5 USD	American	15/01/2027
Common	Call Option	Sold	-6,800	25.0 USD	American	19/12/2025
Common	Call Option	Sold	-1,700	25.0 USD	American	16/01/2026
Common	Put Option	Sold	2,000	17.5 USD	American	19/12/2025
Common	Call Option	Sold	-6,200	12.5 USD	American	19/12/2025
Common	Call Option	Sold	-179,400	10.0 USD	American	16/01/2026
Common	Call Option	Sold	-147,700	15.0 USD	American	16/01/2026
Common	Call Option	Sold	-5,100	10.0 USD	American	19/12/2025
Common	Call Option	Sold	-34,200	5.0 USD	American	15/01/2027
Common	Call Option	Sold	-30,000	15.0 USD	American	20/03/2026
Common	Put Option	Sold	24,900	7.5 USD	American	16/01/2026
Common	Call Option	Sold	-9,600	7.5 USD	American	16/01/2026
Common	Call Option	Sold	-20,800	17.5 USD	American	19/12/2025
Common	Put Option	Sold	4,400	17.5 USD	American	16/01/2026
Common	Put Option	Sold	27,700	20.0 USD	American	19/12/2025
Common	Call Option	Sold	-13,400	10.0 USD	American	15/01/2027
Common	Call Option	Sold	-7,500	7.5 USD	American	15/01/2027
Common	Call Option	Sold	-100	35.0 USD	American	16/01/2026
Common	Call Option	Sold	-100	30.0 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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