I. INTRODUCTION

1. This is an arbitration brought before the International Centre for Settlement of Investment Disputes (“ICSID”) under the Convention on the Settlement of Investment Disputes between States and Nationals of other States dated 18 March 1965 (“ICSID Convention”) and the Agreement Between the Government of the Republic of France and the Government of the Republic of Peru for the Promotion and Reciprocal Protection of Investments dated 6 October 1993 (“France-Peru BIT” or “BIT” or the “Treaty”).1

A. THE PARTIES

1. The Claimants

2. The Claimants in this arbitration are Ms. Renée Rose Levy (“Ms. Levy”), a French national, and Gremcitel S.A. (“Gremcitel”), a company organized under the laws of the Republic of Peru, with its offices in Lima (jointly, “the Claimants”).

3. The Claimants have been represented in this arbitration by: