Member Info for Yaryls

While the claims are treated as distinct legal entities and tracks, the underlying damages regarding the Sidi El Kilani (SLK) concession do fundamentally overlap.

The $130 million ICC-2 claim regarding SLK is effectively absorbed or mirrored within the broader $572.65 million ICSID treaty claim. If Zenith were to fully win the ICC-2 annulment and subsequent award from the Swiss/ICC track, that $130 million would have to be deducted from the final ICSID payout to legally prevent double recovery.

Because the initial ICC-2 tribunal dismissed the $130 million claim, Zenith has deducted nothing from the ICSID claim. The full scope of those losses is currently being pursued via the ongoing ICSID arbitration tribunal.

The company accounts deal with the arbitrations as two separate legal processes hence the two amount are there but they can't be added together to get to $700 however attractive that may seam! Andrea has confirmed in interviews the above.

Candlestick - Andrea has gone on record (Zak Mir interview 5th February 2026) as saying ICC2 claims are included in the ICSID arbitration. This is a transcript from 23" in: "Yes, nearly nearly. So we are making a quite um final six months of this long journey of three years in three arbitration against the Republic of Tunisia. Uh and this one is more important for two reason. First is that is the biggest claim is 573 million American dollars which is quite an important amount. And second is the fact that we have in this instrument which is the ICSID which is an instrument of the world bank of Washington a umbrella case which covers all the other previous contractual arbitrations in the ICC in Paris. So uh anything that has happened before uh is wrap up and then if we have won something we have to deduct it from the claim. If we didn't win we have to deduct nothing. So the amount that we are claiming is 573 million American dollars." Given what he said although there is a hypothetical figure of $700m dollars when double counting, the real world figure is a total of $573m.

""The Swiss Federal Court usually renders decisions on annulment applications within 6 to 9 months from submission."

15 September 2025 to 15 June 2026 is 9 months!!"

Tunisia formally challenged the authority of the Swiss Federal Supreme Court to hear or rule on the annulment application, almost certainly a delaying tactic to push the annulment decision beyond the ICSID hearing. Very unlikely to succeed as a challenge but highly likely to delay the annulment decision by 6 months or so.

If the Annulment for ICC-2 is approved then the previous award (zero) is nullified not turned into a positive award (for Zenith) .

Although Zenith consider ICC-2 and ICSID to be separate processes, which they are, all of the losses claimed through the ICC-2 arbitration are also included in the ICSID claim. Had Zenith won ICC-2 the loses within that claim would have been removed from ICSID lowering the total claim by the ICC-2 claim ($130m).

I can see no situation where ICC-2 arbitration will be pursued regardless of the outcome of the annulment process as there would be no point to expend further energy and legal costs when the ICSID is an umbrella claim.

I read that, thank-you.

Though it is hard to understand why an influx of US$4.3m hardly moves the dial if that is the case.

Great news the rig has been sold and for a very decent price.

The Oslo market appeared to reflect this news 24 hours before the RNS, is Zenith controlling the news flow tightly enough?

Is Zenith being run as a personal fiefdom for the benefit of the Cattaneo family?

"It's understandable to think that devaluation is a step backward, but really, 3.4% is nothing within the grand scheme of things. We have just passed through a milestone point of the companies history. A claim of $570m, with first signs looking good, this could not be any better. Not only that, within the next few months we have an excellent chance of winning the annulment, ICC-2 for $130m."

In isolation 3.4% doesn't sound so bad but in reality it is 58% over 18 months and nearer 65% if the new convertible loan and existing warrants are factored in, so a huge drop.

Zenith had been applauded for financing their own legal costs instead of going the litigation funding route - in hindsight the chunk of the pie a litigation funder may have taken would have been much lower than the dilution caused by the multiple placements, loans and warrants.

Also a heads up; the ICC2 arbitration claims are all included in ICSID so there is no financial upside for a successful ICC2 annulment .

I also see confused messaging over the convertible loan, this has the potential of creating another 28 million shares. If the arbitration is successful then that could end up as a cost of £15m to raise £2m.

If you were really confident in a successful outcome of ICSID why wouldn't you raise short term funding at say 30% interest rates? and at the convertible loan cost any solar profits will be absorbed many times - so why use this loan money on the solar development.

I guess there is a really urgent need for cash - my back of a beermat calculation of the ICSID hearing was £100,000 per day.

Regardless of what AC says I would expect a fair number of shareholders will be pretty disappointed with this. He clearly stated at the last raise in December, "I am fully conscious of the painful dilution, and I am pleased to confirm that we do not anticipate conducting any further equity issuances for any of our existing activities until June 2026 at the very earliest following the Financings."

So this rather goes against those "placating" words to shareholders who once again were excluded.

There have been so many raises over the past 18 months that for each £1 a shareholder might have received as a special dividend form a successful arbitration claim they would now only receive 42p, a dilution of 58% and that is not to mention another 84m warrants lurking in the background.

As a loyal shareholder for over 8 years this comes across as a kick in the teeth, and it is worth mentioning that the raise at NOK 0.87 doesn't look so good when the share price last week was NOK 1.22.

"They are due to start building the solar farms in July, so that is the reason for a cash raise around June.

Couple of £million needed probably."

Well lets say they go to raise £2m in June that is 4% of the current market cap.

If (fingers crossed!) they are successful in the ICSID arbitration the company value in 6 months could be £400m+. From a current shareholders perspective that £2m cash injection would have cost £16m. Whilst I applaud the move into solar it can't be ignored that the major play is the arbitration and looking at it through those eyes a placing to raise cash would be very costly.

Emmerson and First Class Minerals both recently did raises and in both cases enabled their shareholders to participate, unfortunately Zenith have never done this .

So my preference would be for there to be no raise - perhaps focus on completing the rig sale or using as much finance as would be available, but if there had to be one at least let the long suffering shareholders have their bite at the cherry!

"I am fully conscious of the painful dilution, and I am pleased to confirm that we do not anticipate conducting any further equity issuances for any of our existing activities until June 2026 at the very earliest following the Financings." Andrea Cattaneo.

Only 5 weeks away, then again an injection of $2m from a sale of the rig would certainly help, no news on that front though.

I was surprised to hear Antonio mention the idea of settlement with Tunisia in his recent interview. Previously he has exhibited considerable anger over the behaviour of the Tunisians. Add the recent application to the Parisian prosecutor to bring criminal charges against the ICC2 chair I would imagine relations between Zenith and Tunisia to be pretty frosty.

Nevertheless if settlement is on the table what do people think the amount might be. 59% of ICSID cases are settled, those that settle average 34% of the full claimed amount , in Zenith case $572.65m . That would equate to a settlement figure of $194.7m. Given Antonios frequent statements on the strength of their case I can't see them settling at a figure this low. Any other posters care to estimate a settlement amount?

Tunisia used a delaying tactic (contesting the court's jurisdiction). Though it was a challenge that will surely fail it has had the effect of kicking the result into the long grass (legal cogs turn slowly) and beyond the ICSID hearings. Once the result is known it can be communicated officially to ICSID even post hearing. This behaviour by Tunisia may not be to their ultimate benefit.

Given that there is almost no chance in Tunisia successfully challenging the jurisdiction of the Swiss Court to determine the ICC2 appeal their tactic is a brazen attempt to push any decision beyond the dates of the ICSID hearings. Given how slowly legal cogs turn they will, fairly certainly, be successful in this move. Whether it backfires on them only time will tell but I could envisage the ICSID chair taking note of Tunisia's behaviour in this regard. The ICC2 annulment decision could now be as late as the 4th quarter.

However if there was a successful annulment decision post the ICSID hearings but prior to the ICSID decision, which is highly likely, then it could be incorporated in post hearing briefs and end up becoming a double edged sword for Tunisia.

So timelines of last possible dates indicate annulment decision late 2026, ICSID decision spring 2027 - a fair while yet.

Well I had all my bid money debited then, just now, received a penny back (two days later) - so this would be a preliminary indication of 100%? though won't know for sure until the shares are issued.

Unfortunately the delay isn't particularly costly for Poland - if they had to issue sovereign debt to settle they would likely be incurring 5.5% or even a fraction more on the respective bonds, so maybe a .25% to .5% cost?

If Zenith do another round of fund raising, hopefully not, then it would be good if they would follow Emmerson's (EML) lead and allow their loyal investors to participate.

I don't believe Zenith will lodge another ICC 2 claim in the event of annulment, the reason being all the sums claimed in the ICC 2 arbitration are also included in the ICSID main claim, so no further delays or additional legal costs.

This is disappointing for shareholders.

It appears Andrea Cattaneo has been granted a total of 32,159,573 stock options within the last 12-months - this is right up (99%) to the limit of the scheme approved by shareholders, the company itself is also near the total plan limit of 10%. I can't see how it would be in the interests of shareholders to permit renewal of the options scheme when voting at the next AGM otherwise this massive dilution, when added to all the other placements could continue ad infinitum.