RECOMMENDED CLAUSES
FUTURE DISPUTES
For contracting parties who wish to have future disputes referred to arbitration and/or mediation
under the auspices of the LCIA, the following clauses are recommended. Words/blanks in square
brackets should be deleted/completed as appropriate.
Arbitration only
“Any dispute arising out of or in connection with this contract, including any question regarding its
existence, validity or termination, shall be referred to and finally resolved by arbitration under the
Rules of the LCIA, which Rules are deemed to be incorporated by reference into this clause.
The number of arbitrators shall be [one/three].
The seat, or legal place, of arbitration shall be [City and/or Country].
The language to be used in the arbitration shall be [ ].
The governing law of the contract shall be the substantive law of [ ].”
Mediation only
“In the event of a dispute arising out of or relating to this contract, including any question
regarding its existence, validity or termination, the parties shall seek settlement of that dispute by
mediation in accordance with the LCIA Mediation Rules, which Rules are deemed to be
incorporated by reference into this clause.”
Mediation and Arbitration
“In the event of a dispute arising out of or relating to this contract, including my question regarding
its existence, validity or termination, the parties shall first seek settlement of that dispute by
mediation in accordance with the LCIA Mediation Rules, which Rules are deemed to be
incorporated by reference into this clause.
If the dispute is not settled by mediation within [ ] days of the commencement of the
mediation, or such further period as the parties shall agree in writing, the dispute shall be referred
to and finally resolved by arbitration under the LCIA Rules, which Rules are deemed to be
incorporated by reference into this clause.
The language to be used in the mediation and in the arbitration shall be [ ].
The governing law of the contract shall be the substantive law of [ ].
In any arbitration commenced pursuant to this clause,
(i) the number of arbitrators shall be [one/three]; and
(ii) the seat, or legal place, of the arbitration shall be [City and/or Country].”