All disputes and differences arising under or in connection with this contract shall be referred to arbitration under ARIAS Asia Arbitration Rules.


The Arbitration Tribunal shall consist of three arbitrators, one to be appointed by the Claimant, one to be appointed by the Respondent and the third to be appointed by the two appointed arbitrators.


The third member of the Tribunal shall be appointed as soon as practicable (and no later than 28 days) after the appointment of the two party-appointed arbitrators.  The Tribunal shall be constituted upon the appointment of the third arbitrator.


The Arbitrators shall be persons (including those who have retired) with not less than ten years’ experience of insurance or reinsurance within the industry or as lawyers or other professional advisers serving the industry.


Where a party fails to appoint an arbitrator within 14 days of being called upon to do so or where the two party-appointed arbitrators fail to appoint a third within 28 days of their appointment, then upon application ARIAS Asia will appoint an arbitrator to fill the vacancy.  At any time prior to the appointment by ARIAS Asia, the party or arbitrators in default may make such appointment.


The Tribunal may in its sole discretion make such orders and directions as it considers to be necessary for the final determination of the matters in dispute.  The Tribunal shall have the widest discretion permitted under the law governing the arbitral procedure when making such orders or directions.


The seat of arbitration shall be ……………………..


The proper law of this arbitration clause shall be the law of ………………………….