Summary

1. Petitioner Axis Mineral Resources SA ("Axis"), by and through its undersigned counsel, petitions this Court for an order under Section 206 and/or Section 4 of the Federal Arbitration Act ("FAA") compelling Respondent the Republic of Guinea ("Guinea") to arbitrate disputes the Parties have entrusted to resolution by arbitration.

2. Axis and Guinea's relationship stems from a mining permit issued under Decree D/2018/267/PRG/SGG, dated November 2, 2018 (the "Operating Permit"), by means of which Guinea granted Axis the exclusive right of reconnaissance, prospecting, operation, and free disposal of bauxite within a certain area, in exchange for Axis's agreement to pay Guinea certain specified fees, duties, royalties, and costs and preferring Guinean workers, among other things.

3. The Parties' relationship was subject to and incorporated Law L/2011/006/CNT of September 9, 2011, of the Mining Code of the Republic of Guinea, as amended by Law L/2013/053/CNT of April 8, 2013 (the "Mining Code"), which allows an aggrieved party to submit any disputes arising out of the mining relationship to international arbitration in a seat of that party's choosing.

4. On May 14, 2025, the President of Guinea issued "Decree D/2025/0067/PRG/CNRD/SGG on the Withdrawal of Mining Concessions, Industrial Operating Permits and Semi-Industrial Operating Permits Granted to Companies" (the "May 14 Decree"), pursuant to which Guinea unlawfully purported to revoke Axis's Operating Permit.

5. This purported revocation was contrary to Guinean law for numerous reasons, including that it lacked proper notice and a proper ground for revocation.

6. Since the May 14 Decree, Axis has attempted to amicably resolve this dispute, but Guinea has been unresponsive.

7. On July 10, 2025, Axis exercised its rights under the Operating Permit and Mining Code and served Guinea with a notice of arbitration, which commenced an ad hoc international arbitration in New York City, proposing application of the (2018) CPR International Non-Administered Arbitration Rules ("CPR Rules"), published by the International Institute for Conflict Prevention & Resolution ("CPR"), before a three-person tribunal (the "Notice of Arbitration").

8. Guinea has refused to participate in the arbitration.

9. Therefore, Axis brings this petition to compel Guinea to arbitrate this dispute in the manner in which Axis has proposed or, alternatively, as the Court may direct.

...