In light of such diversity, parties may have different expectations regarding the effect of their substantive rights under the contract, or the process and treatment of disputes, when these arise.

With respect to standardised construction contracts (which help to conform divergent expectations), perhaps none are better known than the suite of contracts published by the Fédération Internationale des Ingénieurs-Conseils (“FIDIC ”), which are commonly used throughout the Middle East. 

Among other things, the different forms of FIDIC Contracts reflect different procurement approaches (particularly regarding design responsibility). For instance, while the “FIDIC  Red Book”  is scoped around works predominantly designed by the Employer, the “FIDIC  Yellow Book” is used for works primarily designed by the Contractor.  Additionally, the “FIDIC Silver Book” is intended for use on turnkey projects while the “FIDIC Gold Book” is appropriate for ‘Design-Built-Operate' projects.