I. INTRODUCTION AND OVERVIEW OF THE APPLICATION

1. This case concerns an application for annulment of the award rendered on July 2, 2013 in the arbitration proceeding between Kılıç İnşaat İthalat İhracat Sanayi ve Ticaret Anonim Şirketi (“Applicant” or “Kılıç”) and Turkmenistan (“Turkmenistan” or “Respondent”) (ICSID Case No. ARB/10/1), as rectified on September 20, 2013 and incorporating the Tribunal’s Decision on Article VII.2 of the Turkey-Turkmenistan Bilateral Investment Treaty of May 7, 2012 (the “Award”).

2. The application, dated January 13, 2014, was filed on January 16, 2014, in accordance with Article 52 of the Convention on the Settlement of Investment Disputes between States and Nationals of Other States dated March 18, 1965 (the “ICSID Convention”), and Rule 50 of the ICSID Rules of Procedure for Arbitration Proceedings (the “Arbitration Rules”) (the “Application”). The Application was submitted within the time period provided for in Article 52(2) of the ICSID Convention.

3. The original dispute was submitted to the International Centre for Settlement of Investment Disputes (“ICSID” or the “Centre”) on the basis of the ICSID Convention and the Agreement between the Republic of Turkey and Turkmenistan Concerning the Reciprocal Promotion and Protection of Investments signed in Ashgabat, Turkmenistan on May 2, 1992, which entered into force on March 13, 1997 (the “BIT” or “Treaty”).

4. Applicant, Claimant to the original proceeding, is a construction company with registered offices in Istanbul, Turkey.