Summary

Petitioner Refinería Madero Tamaulipas, S.A.P.I. de C.V. ("Refinería Madero" or "Petitioner"), by and through its attorneys, alleges as follows in support of its petition to confirm and enforce a foreign arbitral award (the "Petition"), pursuant to the United Nations Convention on the Recognition and Enforcement of Foreign Arbitral Awards of June 10, 1958, 21 U.S.T. 2517 (the "New York Convention"), the Inter-American Convention on International Commercial Arbitration of January 30, 1975, 1438 U.N.T.S. 245 (the "Panama Convention"), and Chapters 2 and 3 of Title 9 of the Federal Arbitration Act (the "FAA"). This Petition concerns a foreign arbitral award dated June 30, 2025 (the "Final Award"), rendered in the arbitration between Petitioner on the one hand, and Pemex Transformación Industrial, S.A. de C.V. ("Pemex Tri"), on the other hand (the "Arbitration"). As the Final Award indicates, Pemex Tri was formerly known as Pemex Refinacíon. On September 11, 2025, Petitioner filed a request for correction of the Award, and on January 30, 2026, the arbitral tribunal (the "Tribunal") subsequently issued an addendum (the "Addendum"), which corrected certain aspects of the Award.2 The Addendum was served on Petitioner on March 12, 2026. The Final Award, as amended by the Addendum, is the subject of this Petition.

In March 2025, Pemex Tri was dissolved by operation of Mexican law, with Petróleos Mexicanos ("Pemex") assuming all rights and obligations of Pemex Tri. As a result, Pemex is the named respondent in this proceeding and is referred to herein as the "Respondent" (Petitioner and Respondent are referred to individually as a "Party" and collectively as the "Parties").

The Arbitration, captioned Refinería Madero Tamaulipas, S.A.P.I. de C.V. vs. PEMEX Transformación Industrial, was seated in Mexico City, Mexico and conducted under the 2012 Rules of the International Chamber of Commerce ("ICC Rules").