THIS SETTLEMENT AGREEMENT is made on [insert date] (the ‘Settlement Date') between the following parties (each a ‘party' and together the ‘parties'):

PARTIES

(1) [insert name of party] a company incorporated in [insert location] whose registered number is [insert company number] and whose registered office is at [insert registered office] (‘[Name of party]'); and

(2) [insert name of party] a company incorporated in [insert location] whose registered number is [insert company number] and whose registered office is at [insert registered office] (‘[Name of party]').

BACKGROUND

A [The parties are engaged in a dispute regarding [insert details of the dispute, including material facts, potential causes of action and alleged losses] [full details of which are set out in the schedule attached] (the Dispute).

AND/OR

B The parties have issued various claims against each other [relating to certain aspects of the Dispute] (Claims number(s) [insert Claim number(s)]) [as detailed in the claims schedule] (‘the Claims').]

C The parties have agreed to settle [the Claims AND/OR the Dispute] on the terms set out in this Settlement Agreement.