1. Pursuant to Article 10.16 of the United States-Peru Trade Promotion Agreement that was signed on April 12, 2006 and entered into force on February 1, 2009 (the "Treaty")1 and the Arbitration Rules of the United Nations Commission on International Trade Law ("UNCITRAL Arbitration Rules"), the Renco Group, Inc. ("Renco" or the "Claimant") submits this Notice of Arbitration and Statement of Claim against the Republic of Peru ("Peru" or the "State") for claims arising out of Renco's investment in the La Oroya Metallurgical Complex (the "Complex"), including the Contract of Stock Transfer between Empresa Minera del Centro del Peru S.A. ("Centromin") and Doe Run Peru S.R. LTDA ("DRP"), The Doe Run Resources Corporation ("Doe Run Resources"), and Renco, dated October 23, 1997 (the "Stock Transfer Agreement")2 and the Guaranty Agreement between Peru and DRP, dated November 21, 1997 (the "Guaranty"),3 and related agreements. Specifically, Renco seeks full reparation for Peru's multiple violations of the Treaty, including for Peru's breach of the Stock Transfer Agreement and the Guaranty, which qualify as "investment agreements" under the Treaty.

2. This dispute arises from Peru's violations of the Treaty and international law, including Peru's (i) pattern of continuing unfair and inequitable treatment of DRP in violation of Article 10.5 of the Treaty, (ii) pattern of treating DRP less favorably than it treats Centromin and its successorin- interest Activos Mineros in violation of Article 10.3 of the Treaty, (iii) failure to grant DRP adequate extensions of time to complete environmental projects, (iv) failure and refusal to honor its contractual obligations to Claimant, including the obligations to appear in and defend the lawsuits brought by third parties who claim personal injuries, assume responsibility and liability for any damages that any such third parties may be awarded, and indemnify, release, protect and hold Claimant harmless from such third-party claims, and (v) failure to remediate the soil in and around the town of La Oroya.