Submission Agreement—Referring Existing Disputes to Arbitration
Agreement
THIS AGREEMENT is made on [date]
PARTIES
1 [first party] of [address] (the First Party); and
2 [second party] of [address] (the Second Party).
Background
(A) Disputes, differences, controversies and/or claims have arisen between the parties concerning [summarise the matters in dispute].
(B) The parties wish to resolve all such disputes, differences, controversies and/or claims by arbitration.
THE PARTIES AGREE:
1 Terms of reference
All disputes, differences, controversies and/or claims between the parties concerning [set out the matters referred to arbitration] are referred to and shall be determined by arbitration.
2 The tribunal
The arbitral tribunal (the tribunal) shall consist of a sole arbitrator. If the parties fail to agree upon the identity of the sole arbitrator within 30 days of service of the notice of arbitration, the sole arbitrator shall be appointed by [appointing authority], at the written request of either party.
3 Governing law, place and language of arbitration
3.1 The law governing the substantive issues between the parties shall be [Kuwait law].
3.2 The seat of the arbitration shall be [Kuwait].
3.3 The language of the arbitration shall be [English].