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Understanding the Share Structure Across London and Oslo - London requires a prospectus for share issuances, which is expensive and time-consuming (so it is usually updated every two years). As a result, the most up-to-date share count is reflected in Oslo, while London sometimes lags behind.

Oil Field Acquisitions & Growth Strategy -How Zenith Acquires Oil Fields

The lifecycle of an oil field follows this pattern:

• Major companies discover and develop fields and increase production to large quantities, normally over 100,000 barrels per day.

• Over time, production declines, and these companies sell the fields to smaller operators like Zenith.

To acquire such fields, Zenith must:

• Be a certified operator (a rare qualification).

• Be financially stable to avoid tarnishing the reputation of the seller

• Ensure social responsibility, as former employees from major companies will transition to Zenith.

• Demonstrate environmental safety to reassure the host country.

Company Assets

Italy – Mediterranean Oil & Gas Deal In 2010, Zenith acquired the Italian assets of Mediterranean Oil & Gas, a UK-listed energy company that had invested £150 million in Italy. This company failed to turn a profit, leading to a fire-sale of its assets. Zenith acquired the company for a negative consideration (i.e., they were paid to take ownership). Despite seller doubts, Zenith has profited from the asset for 15 years.

USA – Leopard Energy Acquisition - Zenith acquired Leopard Energy, a small oil company listed on the OTC market. Plans to transition Leopard Energy to a higher-tier US exchange (NASDAQ, AMEX, or NYSE) for better market visibility.

Tunisia – CNPC Tunisia and other Tunisian acquisitions.- During 2020 and 2021 Zenith acquired four oil fields, including one from CNPC (China’s largest state oil company). Despite COVID-related travel restrictions, Zenith’s team successfully negotiated and finalized the deals in this two years period. The fields produced nearly 2,000 barrels per day, generating steady revenue until Tunisia seized the assets illegally in 2022. Following this experience, Zenith now prefers investing in legally stable countries.

Post by Market Gun on Norway forum

I was able to watch the video of the Oslo presentation last night and while it did not reveal anything that we did not already know, I think it was helpful to view as it definitely clarified the company’s position on all things Zenith, straight from the CEO’s own mouth.

I have made a bunch of notes on what was said and I thought that I would post my write-up here to act as an aid to discussion and clear up any confusion between the speculation on these boards and what the company is actually saying. I have ordered my notes under the same headings as the company used in the presentation and added my own conclusion.

Company Background

Zenith Energy is a Canadian energy company headquartered in Calgary, a major oil hub alongside Houston. Calgary has a high concentration of oil professionals, with nearly everyone in the city working in oil and gas except for dentists and bartenders. The company’s philosophy and operations are rooted in Calgary’s oil industry expertise.

Zenith went public in autumn 2008, just after the Lehman Brothers collapse, which had a major financial impact on North America. Despite the market turmoil, Zenith was the only energy company to IPO in Canada in the fall of 2008, showing resilience. Initially, the company considered exploration, but later shifted focus to production to ensure steady cash flow. Within 15 months of IPO, Zenith acquired its first oil-producing asset in Argentina, beginning its journey as an operator.

Oil companies can be explorers or producers (operators).Many listed energy companies are merely investors, relying on other firms to operate fields. To qualify as an operator, a company must demonstrate:

• Technical capability to extract and manage hydrocarbons.

• Financial resources to maintain operations.

• Ability to handle environmental risks and prevent contamination.

• Operational safety and compliance with industry regulations.

Zenith prides itself on being a direct operator, rather than a passive investor.

Zenith is primarily listed on the London Stock Exchange (LSE) Main Market and has a secondary listing on Oslo Bors (now Euronext Growth). Oslo Bors provided the most liquid market for Zenith since 2019 , and trading activity has increased significantly in the past 45 days. The company has a market cap of $63 million, with 445 million shares outstanding. Board members include Italians, Mexicans, British, and Chinese professionals, reflecting the international nature of the company.

Zenith initially attempted to acquire assets in Canada, but found the regulatory environment under Prime Minister Trudeau increasingly anti-fossil fuel. Over the last decade, Canada’s oil industry declined significantly, with listed oil companies dropping from 550 to just 75 today. In 2016, Zenith moved its primary listing from Canada to London, later listing in Oslo in 2018.

Massive volumes of trading so far today. Over 40 million shares traded in the first two hours on Euronext. But what does this mean?

A look at recent data highlights this sharp increase:

• November: 9.4M shares traded

• December: 135M shares traded

• January (to date): 300M+ shares traded

o Jan 1–24: 176M shares

o This week (as of Thursday morning): 120M shares

o Last three days (from 28th): 100M shares

The average daily volume for January has been 15M, but over the last three days, it has more than doubled to 31M. The share price has skyrocketed—doubling since 24th January and already quadrupling between late November and late January.

The initial rise was clearly driven by the success of the first arbitration and anticipation of a second victory. However, the surge in both price and volume over the past few days suggests additional factors at play.

In short, something is clearly up. A plausible explanation is that new investors are entering, recognising the potential for significant gains even at current levels. But why now? A tweet today from Lady of Aim suggests that settlement discussions are intensifying, and the trading pattern supports this rumour. While some early investors are taking profits (some of them have made 10 times their money since early November) but the substantial buying activity indicates strong confidence in further upside.

If institutional investors believe a settlement is imminent—potentially at 50% of the claim’s value ($315M)—the share price could increase sixfold from current levels. For an institution investing $2–3M now, the potential return would be highly attractive. Hell, it wouldn’t even surprise me if it was Tunisian officials putting in their own money to Zenith if they knew that a settlement was imminent. Stranger things have happened…

Obviously, I have no evidence for the theory on settlement other than the posts from Lady of Aim, and the idea of the Tunisian official investing is (mostly a joke. However, one undeniable fact remains: the extraordinary trading volume signals that something significant is unfolding. The question is—what?

What splendid news for all Zenith shareholders. The company has reached an extraordinary milestone with the triumphant outcome of the first arbitration. As of today, the company finds itself $10 million to the good. While the enforcement of the judgment remains pending, the announcement assures us that the ruling is enforceable in every jurisdiction worldwide, rendering the recovery of this sum a relatively straightforward matter.

The award itself represents a cash sum amounting to nearly 150% of the company’s current market capitalisation. Once secured, this will constitute a transformative boost for Zenith, materially strengthening its balance sheet. This substantial influx of capital will also facilitate the acquisition of assets that were previously beyond the company’s financial reach, thereby elevating Zenith’s strategic position and growth prospects considerably.

Perhaps the most significant implication of this success lies in the precedent it establishes for the two remaining arbitration cases. Achieving victory in the initial case against Tunisia/ETAP serves as a critical foundation for securing favourable outcomes in the subsequent cases.

The arbitration has definitively confirmed that ETAP acted in bad faith towards Zenith. While ETAP is formally distinct from the Tunisian state, it operates under the direct oversight of the Ministry of Industry, Mines, and Energy and functions as a wholly state-owned enterprise, overseeing hydrocarbon and exploration activities across the country. In effect, ETAP is an arm of the state in all but name.

This ruling, therefore, casts aspersions not only on ETAP but, by extension, on the Tunisian state itself. The legal confirmation of ETAP’s misconduct will inevitably bear significant weight in the second and third arbitrations. Zenith can now cite this judgment as unequivocal evidence of the damages inflicted by the Tunisian state, transforming what was once a matter of opinion into a legally established fact. This development substantially fortifies Zenith’s position in the forthcoming cases.

This victory represents a watershed moment for all of us, bringing to a close what has been a horrible 2024 for all shareholders. With today’s judgment secured, the company’s outlook for 2025 and beyond appears exceedingly promising.

ZENITH ENERGY LTD.

("Zenith" or the "Company")

Positive Result in ICC-1 Arbitration against ETAP

Zenith Energy Ltd. ("Zenith" or the "Company") (LSE: ZEN; OSE: ZENA; OTC PINK: ZENAF), the listed international energy production and development company, is pleased to announce that it has now received the final decision of the Arbitral Tribunal in relation to the claims presented by its fully owned subsidiary registered in Barbados, Ecumed Petroleum Zarzis Ltd ("EPZ"), against the national oil company of the Republic of Tunisia, Entreprise Tunisienne d'Activités Pétrolières ("ETAP"), before the International Chamber of Commerce (ICC) in Paris ("ICC-1 Arbitration).

Background

The ICC-1 Arbitration was commenced following ETAP's failure to comply with its contractual obligations to pay for oil produced and sold by EPZ in Tunisia.

On November 29, 2023, the Company announced that the Arbitral Tribunal had rejected ETAP's request to include the Republic of Tunisia as co-defendant and ordered ETAP to pay approximately EUR 120,000 in costs.

Final Decision - Award

The Arbitral Tribunal has ordered ETAP to pay a principal amount of US$6,139,539, reflecting a revision in the price of Brent crude oil used as a basis of calculation, approximately US$2,700,000 late payment interest levied up to the day of the ICC-1 Arbitration decision, US$395,000 as reimbursement for procedural costs associated with the ICC-1 Arbitration, and US$450,000 in legal costs for a total amount of approximately US$9.7 million.

Interests in connection with late payment will continue to be levied until full recovery of the Award is made.

The ICC-1 Arbitration award, in accordance with article 35.6 of the applicable ICC Rules, is final and may not be appealed by the parties. It is immediately enforceable and capable of being granted execution by any competent court.

Andrea Cattaneo, Chief Executive of Zenith, commented:

"We are very pleased to have now concluded the first chapter of our journey in international legal arbitrations with a victory, confirming the merit of our position and representing formal recognition of the damages we have suffered because of the arbitrary conduct of the Tunisian authorities.

Our sole focus shall now turn to the ICC-2 and ICSID arbitrations with the goal of seeking redress for the significant damages the Company has suffered in Tunisia in relation to its oil production and development portfolio, with claims of US$130 million and US$503 million respectively.

The final decision in respect of ICC-2 is expected by the close of February 2025 with the publication of the decision expected during the summer of 2025. The hearings for the ICSID Arbitration are expected to take place during December 2025, with a final decision expected in the first or second quarter of 2026.

The ICC-1 Award is testament to the resilience of Zenith that has been able to wholly shoulder the sizeable burden of costs inherent to intern

Source FS

To provide a comparison between Zenith and GreenX's claims, it's important to highlight several key factors that differentiate Zenith's situation from that of GreenX (formerly Prairie Mining) in their dealings with the Polish government:

Acquisition and Investment:

GreenX (Prairie Mining) acquired the Debiensko mine for €500k in 2016, along with ownership of the Jan Karski mine, and invested approximately A$4 million into these projects before they were halted by the Polish government.

In Zenith’s case, $6 million was effectively taken by the Tunisian authorities, a more direct and immediate loss of capital. This money was linked to production assets, giving Zenith a more established revenue-generating foothold in Tunisia compared to GreenX’s undeveloped mines.

Nature of Government Actions:

The Polish government issued a formal decree banning the development of GreenX’s projects, following their own legal processes. While GreenX faced a significant setback, the government's actions, although damaging, were taken through a legal and transparent framework.

In contrast, the Tunisian government’s actions in Zenith’s case appear to have involved no formal legal process, constituting a direct, unlawful seizure of assets, which strengthens the validity of Zenith’s claim.

Production Status:

At the time of the ruling against GreenX, they had no active production at either of their sites. Any potential revenue was based on future developments, which required significant investment and time.

Zenith, on the other hand, had significant production in place in Tunisia, meaning that Zenith had a revenue stream already established, making the loss more immediate and quantifiable in terms of current earnings and operational capacity.

Scope of the Claim:

GreenX’s claim against Poland included not only the money they invested but also lost future profits and damages, ultimately totalling A$1.3 billion. Their recent ruling resulted in an award of A$490 million, which is roughly one-third of the total claim.

Given Zenith’s stronger case, which involves not just the loss of future earnings but the direct loss of funds and production revenues, it stands to reason that Zenith's case could potentially be awarded a higher percentage of the total claim. If, like GreenX, Zenith were to receive even a third of their claim, it would be a substantial win, though the nature of Zenith’s case could yield a more favourable ruling.

The main reasons Zenith’s claim against Tunisia is likely stronger than GreenX’s case against Poland are:

Direct theft of funds rather than a legally sanctioned ban.

Operational production losses from an already revenue-generating asset.

The fact that Tunisia’s actions bypassed legal channels, making the case more clear-cut.

Precedent from GreenX’s ruling suggests a favourable outcome for Zenith in terms of future losses, but Zenith’s stronger legal footing sug

Taken from FS

“ Here is an arbitration success Greenx just won £252 million against the Republic of Poland. Our case is much stronger so I am very confident we will be winning at least 50% of the money owed.

https://www.londonstockexchange.com/news-article/GRX/compensation-of-ps252m-in-successful-arbitration/16703935 “

GREENX WINS COMPENSATION AND INTEREST TOTALLING £252M MILLION IN SUCCESSFUL ARBITRATION OUTCOME

GreenX Metals Limited (GreenX, Claimant or Company) is pleased to report a successful outcome of the international arbitration claims (Claim) against the Republic of Poland (Poland or Respondent) under both the Australia-Poland Bilateral Investment Treaty (BIT) and the Energy Charter Treaty (ECT) (together the Treaties).

· The Company has been awarded approximately £252m (A$490m / PLN1.3bn) in compensation by the Tribunal under the BIT (BIT Award), which includes interest compounded at the Sterling Over-Night Interbank Average (SONIA) plus one percentage point (+1%) compounded annually from 31 December 2019 to the date of the award (7 October 2024). Interest will continue to accrue at SONIA +1% compounded annually until full and final payment by the Respondent.

· The Company has been awarded approximately £183m (A$355m / PLN 941m) in compensation by the Tribunal under the ECT (ECT Award), which includes interest compounded at the SONIA overnight rate +1% compounded annually from 31 December 2019. Interest will continue to accrue at SONIA +1% compounded annually until full and final payment by the Respondent.

· Both Awards are subject to any payments made by the Respondent to the Claimant in the other arbitration such that the Claimant is not entitled to double compensation i.e., any amount paid by Poland in one arbitration (i.e., BIT) is set off against Poland's liability in the other arbitration (i.e., ECT).

· Each party has been ordered to cover its own legal fees, expenses and arbitration costs in relation to the Claim, which in respect of GreenX are costs that have already been fully paid under the Litigation Capital Management (LCM) funding facility.

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