1. INTRODUCTION

1.1 On 30 December 2009, Claimant, Kılıç İnşaat İthalat İhracat Sanayi ve Ticaret Anonim Şirketi (also referred to as “Kilic”), a company with registered offices in Istanbul, Turkey, filed a Request for Arbitration (“Request”) before the International Centre for Settlement of Investment Disputes (“ICSID” or the “Centre”) alleging breaches by Respondent, Turkmenistan (referred to indistinctively as “Turkmenistan” or “Respondent”) of the Agreement Between the Republic of Turkey and Turkmenistan Concerning the Reciprocal Promotion and Protection of Investments, which entered into force on 13 March 1997 (“BIT”).

1.2 The Request was registered by the Secretary-General of ICSID on 19 January 2010, in accordance with Article 36(3) of the Convention on the Settlement of Investment Disputes between States and Nationals of Other States (“ICSID Convention”).

1.3 Claimant and Respondent are hereinafter collectively referred to as the “parties.” The parties’ respective representatives and their addresses are listed above.