THE PROBLEM

CLAIMANT’s EXHIBIT C 9
Witness Statement Iliena Jaschin
I have a background in finance and am since 2009 the Chief Financial Officer of Wright
Ltd. I deliver this witness statement after having read SantosD’s Answer to the Request of
Arbitration and its Application for Security for Cost. Both give a wrong impression of the
facts which I would like to correct.
The financial situation of Wright Ltd has not changed substantially or unexpectedly
between the conclusion of the Development and Sales Agreement in 2010 and the
initiation of these arbitration proceedings. For companies of the size of Wright Ltd the
development of a new fan blade is normally associated with a considerable financial effort
largely depleting the freely available financial means. Once the sale of the newly
developed fan blades starts liquid means are built up again. Consequently, our search for
outside funding of this arbitration or insistence on quick payment is normal as we have
just developed a new generation of fans. The situation was identical to that in the first
month of 2010 were we had also a strained liquidity situation. The infusion of liquidity in
the amount of EQD 1.5 million through our then parent company had been one of the
conditions of the purchaser of Wright Ltd. It was, however, reflected for the first time in
the balance sheet for the year 2010 published in February 2011.
Equally, our claim against the Government of Xanadu was reflected in our 2010
international balance sheet with US$ 15 million which we considered to be very
conservative at the time. It may well be that our CEO or other persons of the negotiation
team had given different expectation to the general public or RESPONDENT, but the
balance sheet always only included the claim with a value of US$ 15 million which is not
too different from the amount finally received.
Last but not least Mr Romario’s description of the previous contracts is not completely
correct. In fact, under both contracts the exchange rate at the time of contract conclusion
was applied to convert the costs incurred into US$. Both times that has, however, been the
result of discussions at the time of payment. In one case it did not really matter, as the
exchange rate at the time of contract conclusion was identical to that of the time when the
costs were incurred and that when payment was made. In the other case, concerns of
liquidity management in the Engineering International SA group led to the decision in
favor of applying the exchange rate at the time of contract conclusion.
Before signing the addendum Ms Beinhorn had asked me whether we could agree for the
clamps to a fixed exchange rate. Given the limited size of the contract I agreed. In light of
that request I am convinced that Ms Beinhorn would not have agreed on a fixed rate for
the fan blades.
Equatoriana, 15 September 2016
[Signature]Iliena Jaschin
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