Summary

INTRODUCTION

1. By summons dated 13 November 2025 ("Summons"), the Defendant seeks specific discovery of documents listed in the schedule to the Summons ("Schedule"), namely:

"1. Pleadings and written submissions (including any exhibits thereto) in the arbitration proceedings commenced by the Plaintiff against TECNIMONT S.p.A. and TECNIMONT Arabia Ltd (collectively, the "Tecnimont Entities") on 11 November 2020 with the International Chamber of Commerce ("ICC") (ICC case no. 25791/AZR) (the "Tecnimont Arbitration"), including but not limited to:

a. The Request for Arbitration filed by the Plaintiff on 11 November 2020;

b. The Answer to the Request for Arbitration filed by the Tecnimont Entities on 2 February 2021;

c. The Statement of Claim filed by the Plaintiff on 22 December 2021;

d. The Statement of Defence filed by the Tecnimont Entities on 12 April 2022; and

e. The "second exchange of briefs between the parties... between August and November 2022" referred to in MAIRE S.p.A.'s 2024 Annual Financial Report published in or around 4 March 2025 (the "Report");

2. The Terms of Reference dated 6 October 2021;

3. Documents produced by way of disclosure in the course of the Tecnimont Arbitration;

4. Witness evidence given in the course of the Tecnimont Arbitration, including but not limited to:

a. Witness statements; and

b. Transcript of proceedings recording the testimony given by all the witnesses at the hearing(s); and

5. Order(s), ruling(s) and award(s) in the Tecnimont Arbitration, including but not limited to:

a. "Procedural Order No.1 which included the procedural schedule" after the Case Management Conference in May 2021 referred to in the Report;

b. Ruling on 15 November 2021 on the two preliminary issues concerning "statute of limitations for [the Plaintiff's] claims under the contracts, and the eventual settlement of those claims as a result of the Global Settlement Agreement entered into between the parties at the time of the issuance of the Final Acceptance of Plant Certificate" referred to in the Report; and

c. The Award issued on 23 July 2024."

(collectively, the "Tecnimont Arbitration Materials")

2. The Plaintiff opposes the Summons.