Outcome of ICC-2 & Application for Annulment

16 Jul 2025 19:32 CEST

July 16, 2025

ZENITH ENERGY LTD.

("Zenith" or the "Company")

Outcome of ICC-2 & Application for Annulment

Zenith Energy Ltd. ("Zenith" or the "Company") (LSE: ZEN; OSE: ZENA; OTC PINK:
ZENAF), the listed international energy production and development company,
announces that its wholly owned subsidiary, Canadian North Africa Oil and Gas
Limited (“CNAOG”), has received the decision of the Arbitral Tribunal in respect
of the ICC-2 Arbitration regarding the Sidi El Kilani concession ("SLK
Concession") against the Republic of Tunisia ("ICC-2 ").

Decision

The Arbitral Tribunal has issued a decision rejecting the entirety of the claims
presented by CNAOG.
Application for Annulment

Under the rules of the ICC, a party may apply for annulment of an arbitral award
for, inter alia, cases of procedural irregularities.

The Company confirms that its legal counsel identified and documented several
serious procedural irregularities during ICC-2.

Following legal advice, the Company will now proceed with an application for
annulment of the ICC-2 award before the Swiss Federal Supreme Court in Lausanne,
Switzerland.
The Swiss Federal Supreme Court usually renders decisions on annulment
applications within 6 to 9 months from submission.

Background

CNAOG initiated the ICC-2 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:

• CNAOG's lost production revenue and associated profitability, during a period
of high energy prices, from the SLK Concession until its initial expiry in
December 2022.
• The volume of crude oil produced from the SLK Concession and allocated to and
received by CNAOG upon the completion of the acquisition.
• The value of the 45% interest in the renewal of the SLK Concession,
representing a breach of CNAOG's right to renew its previously existing 22.5%
interest in SLK, as well as the 22.5% interest held by Kuwait Foreign Petroleum
Exploration Company, which relinquished its interest in the SLK Concession
before its initial expiry.
CNAOG filed claims in the amount of approximately US$130 million following
calculations made by third-party experts.

Andrea Cattaneo, Chief Executive Officer of Zenith, commented:

“We are outraged by the decision rendered by the Arbitral Tribunal in ICC-2.
Our position has always been – and remains – that CNAOG is entitled to
substantial compensation with respect to the SLK concession. The failure to
recognize the illegitimate conduct of the Tunisian authorities, following the
favourable precedent set in ICC-1, is nothing short of a travesty.

Acting on the advice of Professor Thomas Clay, a globally recognized authority
in international arbitration, CNAOG had already expressed serious concerns
regarding the management of ICC-2. We identified and promptly documented serious
and repeated procedural irregularities during ICC-2. However, due to the
confidentiality provisions governing ICC-2, we were unable to disclose these
irregularities publicly until now.

The Company is now considering all legal avenues. CNAOG will, without delay,
file an application for annulment of the ICC-2 award before the Swiss Federal
Supreme Court. Should the annulment succeed, a new arbitration will be initiated
under a properly constituted and impartial tribunal.

CNAOG remains fully confident in the strength of its case and will continue to
fight vigorously to achieve justice. Our immediate focus now shifts to the ICSID
arbitration, where we are pursuing a US$503 million claim. The final submission
is scheduled for September 2025, ahead of the final hearing in Q2 2026. At the
same time, we are taking all necessary measures to enforce the ICC-1 award of
approximately US$10 million.
This injustice only serves to strengthen our resolve. The Company will not
hesitate to explore every legal and procedural mechanism available to ensure
accountability and to vindicate its rights.”

Clay Arbitration and Charles Russell Speechlys Paris, Zenith’s legal counsel,
commented:

“After 32-months of proceedings, marked by numerous incidents that the Arbitral
Tribunal proved unable to resolve and equally unable to maintain proper control
over the proceedings, the Tribunal has issued a 70-page arbitral award, with
only 6 pages of reasoning, dismissing all claims totalling US$130 million. This
was done while refusing to apply the applicable legal rules and contradicting a
prior arbitral award.
The countless cases of procedural irregularities were systematically recorded as
formal objections, which will be invoked in the annulment proceedings to be
filed imminently.”


Market Abuse Regulation (MAR) Disclosure

The information included in this announcement is defined as inside information
pursuant to MAR article 7 and is publicly disclosed in accordance with MAR
article 17 and section 5 -12 of the Norwegian Securities Trading Act. The
announcement is made by the contact person.

More information:
Access the news on Oslo Bors NewsWeb site

651380_16.07.2025 - Norway.pdf