Update on ICC-2 Annulment Application
Idag, 01:01
Idag, 01:01
Update on ICC-2 Annulment Application
March 11, 2026
ZENITH ENERGY LTD.
("Zenith"or the"Company")
Update on ICC-2 Annulment Application
Zenith Energy Ltd. ("Zenith" or the "Company") (LSE: ZEN; OSE: ZENA; XSAT: ZENA SDR), the international energy production and development company, is pleased to provide an update regarding the application for annulment (the "Annulment Application") of the ICC-2 Arbitration (the "ICC-2 Arbitration") before theSwiss Federal Supreme Court in Lausanne, Switzerland (the “SwissCourt”) submitted by its wholly owned subsidiary, Canadian North Africa Oil and Gas Limited (“CNAOG”).
The Annulment application was submitted by CNAOG in September 2025 and procedurally accepted by the Swiss Court in October 2025.
The Company confirms that theRepublic of Tunisiafailed to submit its response to the Annulment Application within the required procedural timeframe set out by the Swiss Court and has instead sent a submission to the Swiss Court contesting its jurisdiction. Further, the Republic of Tunisia has advanced a legally unfounded and unreasonable argument that the Annulment Application should be adjudicated by a Court of Appeal seated within the Republic of Tunisia.
The Company will provide an update once further information becomes available, in full compliance with procedural guidelines.
Background
CNAOG initiated the ICC-2 Arbitration against the Republic of Tunisia, as announced in December 2023, following a series of arbitrary actions and obstructions undertaken by the Republic of Tunisia, leading to the arbitrary termination of the SLK concession.
Inter alia, these included:
Application for Annulment
Under the Swiss procedural rules, the Company applied for annulment of an arbitral award for, inter alia, cases of serious procedural irregularities.
As previously disclosed on September 15, 2025, following the ICC-2 Award, the Company became aware of new evidence indicating previously undisclosed connections between two members of the ICC-2 Arbitral Tribunal, including its Chair, Ms. Cecilia Carrara, and the Republic of Tunisia.
Theseundisclosed connectionsand theprocedural irregularities, both during the proceedings and reflected within the ICC-2 Award, constitute thecore foundationfor the Annulment Application.
The Company engagedCharles Russell SpeechlysGeneva, led byPierre Bydzovsky, to prepare and file the Annulment Application.
The SwissCourt usually renders decisions on annulment applications within 6 to 9 months from submission.
Andrea Cattaneo, Chief Executive Officer of Zenith Energy, commented:
“Despite the historically low success rate of annulment applications, we believe that the extent to which the ICC-2 Arbitration was flawed and procedurally irregular, culminating in an Arbitral Tribunal issuing a 70-page arbitral award containing only six pages of reasoning and dismissing claims totalling US$130 million after 32 months of proceedings, is both deeply surprising and disappointing. This occurred after the ICC-2 Arbitral Tribunal refused to apply the applicable legal rules and contradicted the prior arbitral award in ICC-1.
These matters are further compounded by evidence collected and presented in the Annulment Application, which casts significant doubt on the impartiality of two members of the ICC-2 Arbitral Tribunal, including its Chair, Ms Cecilia Carrara. The Chair of the ICC-2 Arbitral Tribunal and another member of the ICC-2 Arbitral Tribunal failed to disclose connections giving rise to a serious conflict of interest with the Republic of Tunisia.
Moreover, the fact that the Republic of Tunisia has failed to submit its response within the required timeframe and has instead challenged the authority of the Swiss Court, asserting that the Annulment Application should be heard in Tunisia, represents yet another example of Tunisia’s consistent efforts to escape justice, as evidenced, amongst other things, by its failure to date to pay any procedural expenses associated with the arbitrations, all of which have been borne by Zenith subsidiaries, including CNAOG. This is emblematic of an ongoing pattern of behaviour characterised by dilatory tactics, non-payment, and attempts to inflict as much financial damage as possible on Zenith’s subsidiaries to hinder their ability to pursue their claims.
Our legal team has worked with dedication and perseverance to present the merits of the ICC-2 Annulment Application clearly and comprehensively. We look ahead with confidence that the Swiss Court will give due consideration to CNAOG’s submissions.”
Further Information:
Zenith Energy Ltd Andrea Cattaneo, Chief Executive Officer | Tel: +1 (587) 315 1279 E: info@zenithenergy.ca |
Notes to Editors:
Zenith Energy Ltd. is a revenue generating, independent energy company with energy production, exploration and development assets in North Africa, the US and Europe. The Company is listed on the London Stock Exchange Main Market (LSE: ZEN), the Euronext Growth of the Oslo Stock Exchange (OSE: ZENA) and on the Spotlight Stock Market in Sweden (XSAT: ZENA SDR).
Zenith's strategic focus is on pursuing development opportunities through the development of proven revenue generating energy production assets, as well as low-risk exploration activities in assets with existing production.
For more information, please visit: www.zenithenergy.ca
Twitter: @zenithenergyltd
LinkedIn: https://bit.ly/3A5PRJb
Market Abuse Regulation (MAR) Disclosure
The information contained in this announcement is information that the Company is required to disclose under the EU Market Abuse Regulation (Regulation (EU) No 596/2014) (“MAR”), as applicable in Sweden and to companies listed on Spotlight Stock Market. The information was submitted for publication, through the agency of the contact person listed above, at the time this announcement was made public. Following publication, this information is now considered to be in the public domain.
Idag, 01:01
Update on ICC-2 Annulment Application
March 11, 2026
ZENITH ENERGY LTD.
("Zenith"or the"Company")
Update on ICC-2 Annulment Application
Zenith Energy Ltd. ("Zenith" or the "Company") (LSE: ZEN; OSE: ZENA; XSAT: ZENA SDR), the international energy production and development company, is pleased to provide an update regarding the application for annulment (the "Annulment Application") of the ICC-2 Arbitration (the "ICC-2 Arbitration") before theSwiss Federal Supreme Court in Lausanne, Switzerland (the “SwissCourt”) submitted by its wholly owned subsidiary, Canadian North Africa Oil and Gas Limited (“CNAOG”).
The Annulment application was submitted by CNAOG in September 2025 and procedurally accepted by the Swiss Court in October 2025.
The Company confirms that theRepublic of Tunisiafailed to submit its response to the Annulment Application within the required procedural timeframe set out by the Swiss Court and has instead sent a submission to the Swiss Court contesting its jurisdiction. Further, the Republic of Tunisia has advanced a legally unfounded and unreasonable argument that the Annulment Application should be adjudicated by a Court of Appeal seated within the Republic of Tunisia.
The Company will provide an update once further information becomes available, in full compliance with procedural guidelines.
Background
CNAOG initiated the ICC-2 Arbitration against the Republic of Tunisia, as announced in December 2023, following a series of arbitrary actions and obstructions undertaken by the Republic of Tunisia, leading to the arbitrary termination of the SLK concession.
Inter alia, these included:
Application for Annulment
Under the Swiss procedural rules, the Company applied for annulment of an arbitral award for, inter alia, cases of serious procedural irregularities.
As previously disclosed on September 15, 2025, following the ICC-2 Award, the Company became aware of new evidence indicating previously undisclosed connections between two members of the ICC-2 Arbitral Tribunal, including its Chair, Ms. Cecilia Carrara, and the Republic of Tunisia.
Theseundisclosed connectionsand theprocedural irregularities, both during the proceedings and reflected within the ICC-2 Award, constitute thecore foundationfor the Annulment Application.
The Company engagedCharles Russell SpeechlysGeneva, led byPierre Bydzovsky, to prepare and file the Annulment Application.
The SwissCourt usually renders decisions on annulment applications within 6 to 9 months from submission.
Andrea Cattaneo, Chief Executive Officer of Zenith Energy, commented:
“Despite the historically low success rate of annulment applications, we believe that the extent to which the ICC-2 Arbitration was flawed and procedurally irregular, culminating in an Arbitral Tribunal issuing a 70-page arbitral award containing only six pages of reasoning and dismissing claims totalling US$130 million after 32 months of proceedings, is both deeply surprising and disappointing. This occurred after the ICC-2 Arbitral Tribunal refused to apply the applicable legal rules and contradicted the prior arbitral award in ICC-1.
These matters are further compounded by evidence collected and presented in the Annulment Application, which casts significant doubt on the impartiality of two members of the ICC-2 Arbitral Tribunal, including its Chair, Ms Cecilia Carrara. The Chair of the ICC-2 Arbitral Tribunal and another member of the ICC-2 Arbitral Tribunal failed to disclose connections giving rise to a serious conflict of interest with the Republic of Tunisia.
Moreover, the fact that the Republic of Tunisia has failed to submit its response within the required timeframe and has instead challenged the authority of the Swiss Court, asserting that the Annulment Application should be heard in Tunisia, represents yet another example of Tunisia’s consistent efforts to escape justice, as evidenced, amongst other things, by its failure to date to pay any procedural expenses associated with the arbitrations, all of which have been borne by Zenith subsidiaries, including CNAOG. This is emblematic of an ongoing pattern of behaviour characterised by dilatory tactics, non-payment, and attempts to inflict as much financial damage as possible on Zenith’s subsidiaries to hinder their ability to pursue their claims.
Our legal team has worked with dedication and perseverance to present the merits of the ICC-2 Annulment Application clearly and comprehensively. We look ahead with confidence that the Swiss Court will give due consideration to CNAOG’s submissions.”
Further Information:
Zenith Energy Ltd Andrea Cattaneo, Chief Executive Officer | Tel: +1 (587) 315 1279 E: info@zenithenergy.ca |
Notes to Editors:
Zenith Energy Ltd. is a revenue generating, independent energy company with energy production, exploration and development assets in North Africa, the US and Europe. The Company is listed on the London Stock Exchange Main Market (LSE: ZEN), the Euronext Growth of the Oslo Stock Exchange (OSE: ZENA) and on the Spotlight Stock Market in Sweden (XSAT: ZENA SDR).
Zenith's strategic focus is on pursuing development opportunities through the development of proven revenue generating energy production assets, as well as low-risk exploration activities in assets with existing production.
For more information, please visit: www.zenithenergy.ca
Twitter: @zenithenergyltd
LinkedIn: https://bit.ly/3A5PRJb
Market Abuse Regulation (MAR) Disclosure
The information contained in this announcement is information that the Company is required to disclose under the EU Market Abuse Regulation (Regulation (EU) No 596/2014) (“MAR”), as applicable in Sweden and to companies listed on Spotlight Stock Market. The information was submitted for publication, through the agency of the contact person listed above, at the time this announcement was made public. Following publication, this information is now considered to be in the public domain.
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