ZENA: Update on ICC-2 Arbitration

September 15, 2026

ZENITH ENERGY LTD.

("Zenith" or the "Company")

Update on ICC-2 Arbitration 
 
Zenith (LSE: ZEN; OSE: ZENA; XSAT: ZENA SDR), the listed 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 seated in Geneva before the Swiss Federal Supreme Court in Lausanne,
Switzerland (the "Swiss Court"), submitted by its wholly owned subsidiary,
Canadian North Africa Oil and Gas Limited (the "Claimant" or "CNAOG").

The Claimant is mindful that the Swiss Court applies a deliberately narrow
standard of review to international arbitral awards. That standard reflects the
finality accorded to arbitration under Swiss law and is one of the reasons why
Switzerland is a leading seat for international arbitration. The grounds relied
upon by CNAOG, including the requirement for an independent and impartial
tribunal, are among those recognised under the applicable Swiss legal framework.

Notwithstanding the limited scope of an appeal before the Swiss Court, CNAOG
remains confident that the Court will issue a decision restoring justice in the
ICC-2 case.

In light of this, the Claimant will engage a leading independent European law
firm with an internationally recognised dispute-resolution practice to advise
the Company in relation to, and prepare and file, an additional application
before the European Court of Human Rights (the "ECHR Application") in connection
with the ICC-2 Arbitration.
The proposed appointment reflects the seriousness with which CNAOG regards the
issues arising from the ICC-2 Arbitration, including the right to a fair hearing
before an independent and impartial tribunal.

The ECHR Application, where necessary, will be pursued and will concern, inter
alia, the Company's right to a fair hearing before an independent and impartial
tribunal, as protected under the European Convention on Human Rights.
As announced on 9 July 2026, CNAOG obtained material which it believes
constitutes additional indication of previously undisclosed and irregular
contact between the President of the ICC-2 Arbitral Tribunal, Ms Cecilia
Carrara, and counsel representing the Republic of Tunisia.

The material includes evidence that Ms Carrara attended conferences in the
Republic of Tunisia during the ICC-2 Arbitration proceedings, including events
featuring the keynote participation of counsel representing the Republic of
Tunisia. CNAOG is also investigating whether payments connected with attendance
at such events may have been made by, or on behalf of, the Republic of Tunisia.
CNAOG considers that these matters should have been disclosed and raise serious
questions concerning the independence and impartiality of the ICC-2 Arbitral
Tribunal.

These matters are in addition to the fundamental procedural concerns already
raised in the Annulment Application. These include an ICC-2 award of
approximately 70 pages, containing only six pages of reasoning, which dismissed
claims totalling approximately US$130 million following 32 months of proceedings
and which CNAOG considers to be inconsistent with the applicable legal framework
and materially at variance with the earlier ICC-1 Award.
The Company will provide further updates as the Annulment Application
progresses, in accordance with its disclosure obligations and applicable
procedural requirements.

Background

CNAOG initiated the ICC-2 Arbitration against the Republic of Tunisia in
December 2022 following a series of arbitrary actions and obstructions which led
to the unlawful termination of the Sidi El Kilani ("SLK") concession.
CNAOG's claims, calculated by independent third-party experts, totalled
approximately US$130 million and included lost production revenue and associated
profitability, crude oil allocated to and received by CNAOG upon completion of
the acquisition, and the value of the 45% interest in the renewal of the SLK
concession.
Under Swiss procedural rules, CNAOG submitted the Annulment Application on the
basis of, inter alia, serious procedural irregularities. The Annulment
Application was procedurally accepted by the Swiss Court in October 2025.

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 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. 
 
 
sed in accordance with MAR\
article 17 and section 5 -12 of the Norwegian Securities Trading Act. The\
announcement is made by the contact person. \
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