I. PRELIMINARY STATEMENT OF INTENT

1. In accordance with Article 9 of the Treaty on the Mutual Encouragement and Protection of Investments between the Government of the Republic of Belarus and the Government of Ukraine dated 14 December 1995 (the “Ukraine-Belarus BIT”), and in accordance with Article 9 of the Treaty on the Mutual Encouragement and Protection of Investments between the Government of Switzerland and the Government of Belarus dated 28 May 1993 (the “Swiss-Belarus BIT”), we hereby give you notice of the existence of a dispute between Mr. Gennady Mykhailenko and United Pipe Export Company Trading AG, on the one hand, and the Republic of Belarus (“Belarus” or the “State”), on the other.

2. Not only did Belarus expropriate our clients’ factory for the production of cold-shaped seamless steel pipes, the first of its kind in Belarus, but following the illegal arrest and lengthy detention without charge by the State Security Agency of Belarus (the Belarus “KGB”) of Mr. Mykhailenko, a foreign investor, as well as an obvious show trial that made a mockery of both justice and due process, Belarus forced our client to spend six full years in a Belarus labor camp in dreadful conditions, being forced to work six days a week and sharing a cell with dozens of other prisoners. To add insult to injury, this foreign investor was forced on a regular basis by prison guards to watch President Lukashenko’s speeches on television, and to listen to them being read to him by guards. Moreover, as regular communication, let alone management of his associated businesses, was impossible due to his imposed captivity in Belarus for six years, the investor’s related businesses and investments quite foreseeably fell into ruins and he lost, quite literally, everything he owned and his life’s work due to the wrongful acts of Belarus.