Introduction

Maritime arbitration represents a specialized form of dispute resolution tailored to address the unique challenges posed by maritime disputes. These disputes often arise from shipping contracts, cargo issues, marine insurance claims, and other related matters. Given the inherently international nature of maritime trade, arbitration serves as a flexible, efficient, and expert-driven alternative to traditional court systems. This article explores the key dispute resolution mechanisms in maritime arbitration, examining their features, processes, and relevance in resolving maritime disputes.

The Role of Maritime Arbitration

Maritime arbitration holds a pivotal role in resolving conflicts within the maritime industry. It is widely preferred for its efficiency, confidentiality, and the expertise it brings to the table. As an alternative to litigation, arbitration offers a structured yet adaptable approach to handling disputes that arise from maritime contracts, navigational incidents, and various other maritime issues. The specialized knowledge of arbitrators in maritime law and industry practices allows for a more precise and informed resolution process.

The efficiency of arbitration stems from its ability to bypass the often lengthy and cumbersome processes associated with traditional litigation. This is particularly advantageous in the maritime industry, where time is of the essence, and delays can lead to significant financial losses. Additionally, the confidentiality of arbitration proceedings helps protect sensitive commercial information and maintain business relationships.

Advantages of Maritime Arbitration

Maritime arbitration offers several distinct advantages that make it an attractive option for resolving disputes:

Expertise

One of the most significant advantages of maritime arbitration is the expertise of the arbitrators. Arbitrators in this field are often seasoned professionals with specialized knowledge in maritime law, shipping practices, and industry norms. This expertise is crucial for effectively addressing and resolving complex technical issues that frequently arise in maritime disputes. For instance, disputes involving intricate shipping contracts, cargo claims, or navigational incidents require a deep understanding of both legal principles and industry practices.

Confidentiality

The arbitration process is generally private, which helps preserve the confidentiality of sensitive information and commercial interests. This is particularly important in the maritime industry, where public disclosure of disputes could potentially harm business reputations and competitive positions. The confidentiality of arbitration proceedings ensures that trade secrets, proprietary information, and sensitive contractual details are protected from public scrutiny.

Flexibility

Arbitration offers greater procedural flexibility compared to court litigation. Parties can agree on procedural rules, timelines, and the selection of arbitrators. This flexibility allows for a more tailored and efficient dispute resolution process, accommodating the specific needs and circumstances of the parties involved. For example, parties can choose to expedite the proceedings or adopt specific procedural rules that align with the nature of the dispute.

Enforceability

Arbitration awards are widely recognized and enforceable under international conventions, such as the New York Convention. This global recognition facilitates the enforcement of arbitral awards across different jurisdictions, providing a reliable mechanism for resolving international maritime disputes. The enforceability of arbitration awards is a significant advantage, ensuring that parties can obtain and enforce remedies across borders.

Key Arbitration Bodies and Institutions

Several international and national institutions play a crucial role in administering maritime arbitration. These institutions provide the necessary framework and support for effective dispute resolution in the maritime sector.

London Maritime Arbitrators Association (LMAA)

The London Maritime Arbitrators Association (LMAA) is one of the most prominent institutions for maritime arbitration. Established in 1960, the LMAA provides a set of procedural rules and guidelines specifically designed to address maritime disputes. These rules ensure a streamlined and efficient arbitration process tailored to the needs of the maritime industry. The LMAA’s prominence and credibility have made it a preferred choice for many maritime disputes worldwide.

International Chamber of Commerce (ICC)

The International Chamber of Commerce (ICC) is a globally recognized arbitration institution that handles a wide range of commercial disputes, including those in the maritime sector. The ICC’s Arbitration Rules offer a comprehensive framework for resolving maritime disputes, known for their adaptability and international reach. The ICC’s global presence and extensive network of arbitrators make it a reliable institution for handling complex maritime disputes.

Singapore Chamber of Maritime Arbitration (SCMA)

The Singapore Chamber of Maritime Arbitration (SCMA) is a specialized institution dedicated to maritime arbitration. The SCMA provides a set of rules tailored to the maritime industry, emphasizing efficiency and cost-effectiveness. The institution is highly regarded for its expertise in handling complex maritime disputes. The SCMA’s strategic location in Singapore, a major global maritime hub, enhances its relevance and accessibility for maritime arbitration.

American Arbitration Association (AAA) / International Centre for Dispute Resolution (ICDR)

The American Arbitration Association (AAA) and its international arm, the International Centre for Dispute Resolution (ICDR), offer arbitration services for maritime disputes. The ICDR provides a global platform for resolving international maritime disputes, leveraging the established framework and expertise of the AAA. The AAA and ICDR’s comprehensive procedural rules and wide network of arbitrators make them suitable for a broad range of maritime disputes.

Maritime Arbitration Rules and Procedures

The rules and procedures governing maritime arbitration are designed to facilitate a fair and efficient resolution of disputes. These rules provide a structured approach while allowing flexibility to accommodate the specific needs of maritime cases.

Procedural Rules

The procedural rules in maritime arbitration typically follow a series of steps to ensure an organized and fair process:

Filing a Claim

The arbitration process usually begins with the filing of a claim. This document outlines the nature of the dispute, the relief sought, and the relevant facts. The claim is submitted to the chosen arbitration institution or directly to the appointed arbitrator, initiating the formal arbitration process. The clarity and detail of the claim are crucial, as they set the stage for the entire arbitration process.

Appointment of Arbitrators

Parties involved in a maritime dispute select arbitrators who possess expertise in maritime law and industry practices. The appointment process may involve mutual agreement between the parties or follow the rules set by the arbitration institution. The choice of arbitrators is crucial, as their specialized knowledge ensures an informed and effective resolution of the dispute. Parties often seek arbitrators with a proven track record in similar disputes.

Preliminary Hearings

Preliminary hearings are conducted to establish procedural rules, set timelines, and address any preliminary issues. These hearings help streamline the arbitration process by ensuring that all parties are on the same page regarding procedural matters. Preliminary hearings can also address any immediate concerns or requests for interim measures, such as injunctions or protective orders.

Discovery and Evidence

Arbitration proceedings include a discovery phase where parties exchange evidence and documentation relevant to the dispute. This phase allows both parties to gather the necessary information to support their claims. The arbitrator may also request additional evidence or expert testimony to clarify technical aspects of the case. The discovery process is designed to be thorough yet efficient, minimizing delays while ensuring that all relevant information is available.

Hearing and Submission

The arbitration hearing involves presenting evidence, arguments, and witness testimony. Both parties have the opportunity to make their case before the arbitrator, who will consider all evidence before rendering a decision. The hearing process is designed to be thorough yet efficient, ensuring that all relevant information is considered. The format and conduct of the hearing can be tailored to suit the specific needs of the dispute.

Award and Enforcement

After considering the evidence and arguments, the arbitrator issues an award. The award is binding on the parties and can be enforced through national and international mechanisms, such as the New York Convention. The enforceability of arbitration awards is a key advantage, providing a reliable resolution to maritime disputes. Parties must navigate the enforcement process to ensure that the award is recognized and enforced in the relevant jurisdictions.

Special Considerations in Maritime Arbitration

Maritime arbitration involves several special considerations that distinguish it from other forms of arbitration:

Technical Expertise

Maritime disputes often involve complex technical and industry-specific issues. Arbitrators with specialized knowledge in maritime law and shipping practices are essential for accurately assessing and resolving these disputes. This expertise ensures that decisions are well-informed and relevant to the specificities of the maritime industry. For instance, disputes related to vessel operations, cargo handling, and navigational practices require arbitrators who understand the technical and operational aspects of the maritime industry.

International Jurisdiction

Maritime disputes frequently involve parties from different jurisdictions, making international jurisdiction a critical consideration. Arbitration provides a neutral forum for resolving such disputes, avoiding jurisdictional conflicts and ensuring a fair process for all parties involved. The ability to choose a neutral venue and apply internationally recognized rules is a significant advantage in maritime arbitration.

Emergency Measures

In urgent cases, parties may request emergency measures to protect their interests pending the resolution of the arbitration. Arbitrators have the authority to issue interim orders or injunctions to address immediate concerns, ensuring that the parties’ rights and interests are safeguarded during the arbitration process. Emergency measures can include orders to preserve evidence, protect assets, or prevent specific actions that could exacerbate the dispute.

The Impact of International Conventions and Agreements

International conventions and agreements significantly influence the practice of maritime arbitration, shaping both the procedural and substantive aspects of dispute resolution.

New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards

The New York Convention is a cornerstone of international arbitration practice. It facilitates the recognition and enforcement of arbitral awards across member states, providing a uniform framework for the international enforcement of maritime arbitration awards. The widespread adoption of the New York Convention ensures that arbitration awards are recognized and enforceable in numerous jurisdictions, enhancing the effectiveness of maritime arbitration. The Convention’s provisions simplify the enforcement process and reduce the potential for legal obstacles.

UNCITRAL Arbitration Rules 

The United Nations Commission on International Trade Law (UNCITRAL) Arbitration Rules offer a comprehensive set of procedural rules for international arbitration. These rules are widely adopted in maritime arbitration, providing a flexible and internationally recognized framework for resolving disputes. The UNCITRAL Rules are known for their adaptability, making them suitable for a wide range of maritime disputes. The rules emphasize procedural fairness and efficiency, ensuring that arbitration proceedings are conducted in a manner that is equitable and effective.

International Maritime Organization (IMO) Guidelines

The International Maritime Organization (IMO) has issued guidelines related to maritime arbitration, emphasizing the importance of adhering to international standards and best practices. These guidelines aim to promote consistency and fairness in maritime dispute resolution, ensuring that arbitration processes are conducted in a manner that aligns with global standards. The IMO’s guidelines serve as a valuable reference for arbitrators, parties, and institutions involved in maritime arbitration.

Challenges and Future Directions in Maritime Arbitration

While maritime arbitration offers numerous advantages, several challenges persist that need to be addressed to ensure its continued effectiveness:

Jurisdictional Issues 

Jurisdictional conflicts can arise when parties are from different legal systems or when the arbitration agreement is ambiguous. Ensuring clarity in jurisdictional matters is essential for avoiding disputes and ensuring effective arbitration. Clear and precise arbitration agreements can help mitigate these challenges, providing a solid foundation for the arbitration process. Parties must carefully draft arbitration clauses to specify the applicable law, venue, and procedural rules.

Enforcement of Awards 

Although the New York Convention facilitates the enforcement of arbitral awards, practical challenges can arise in enforcing awards in certain jurisdictions. Parties must navigate local laws and regulations to ensure successful enforcement. Developing strategies to address these challenges can enhance the reliability of arbitration as a dispute resolution mechanism. Cooperation between international arbitration institutions and national courts can further streamline the enforcement process.

Evolving Industry Practices 

The maritime industry is constantly evolving, with new technologies and practices shaping the landscape. Arbitration practices must adapt to these changes to address emerging issues and maintain relevance in resolving maritime disputes. Continuous training and development for arbitrators, along with updates to arbitration rules, can help ensure that maritime arbitration remains effective and responsive to industry developments. Innovations in digital documentation, electronic evidence submission, and virtual hearings are examples of how arbitration practices can evolve to meet industry needs.

Conclusion

Maritime arbitration is a vital mechanism for resolving disputes in the maritime industry, offering expertise, confidentiality, and efficiency. The various dispute resolution mechanisms, institutions, and rules play a crucial role in ensuring that maritime disputes are resolved effectively and fairly. As the maritime industry continues to evolve, the arbitration framework will need to adapt to address new challenges and maintain its effectiveness in resolving complex maritime conflicts. By addressing these challenges and leveraging the strengths of arbitration, the maritime industry can continue to benefit from a reliable and efficient dispute resolution mechanism.

The future of maritime arbitration lies in its ability to adapt to changing industry dynamics, technological advancements, and evolving legal landscapes. By fostering international cooperation, enhancing procedural efficiency, and maintaining a focus on specialized expertise, maritime arbitration can continue to provide a robust and effective means of resolving disputes in one of the world’s most critical and dynamic industries.

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International arbitration has emerged as the preferred mechanism for resolving cross-border commercial disputes in an increasingly interconnected global economy. This alternative dispute resolution method allows parties from different jurisdictions to settle their disagreements outside traditional court systems through binding decisions made by neutral arbitrators. The framework governing international arbitration comprises multilateral treaties, institutional rules, and national legislation that work together to create a predictable and enforceable system for dispute resolution across borders.

Understanding International Arbitration

International arbitration refers to a process where parties to a dispute agree to have a neutral person or panel reach a binding decision based on previously agreed-upon norms and rules [1]. This mechanism differs from domestic arbitration primarily because it involves parties from different states or disputes with international elements. The process maintains a careful balance between party autonomy and institutional oversight, allowing disputing parties to customize many aspects of their proceedings while ensuring fundamental procedural fairness.

The distinction between international and domestic arbitration extends beyond mere geography. An arbitration is considered international when the parties have their places of business in different states at the time of making their agreement, or when a substantial part of the transaction occurred in different states [2]. This definition captures the truly transnational character of modern commercial relationships where businesses operate across multiple jurisdictions simultaneously.

Primary Legal Frameworks Governing International Arbitration

The New York Convention 1958

The Convention on the Recognition and Enforcement of Foreign Arbitral Awards, commonly known as the New York Convention, stands as the cornerstone of the international arbitration system [3]. Adopted on June 10, 1958, and entering into force on June 7, 1959, this treaty has achieved remarkable success with over 169 contracting states as of recent counts. The Convention fundamentally transformed international arbitration by creating a uniform framework for recognizing and enforcing foreign arbitral awards across borders.

The New York Convention requires national courts to recognize and enforce foreign arbitral awards and arbitration agreements subject to specific limited exceptions. Article III of the Convention establishes that each contracting state shall recognize arbitral awards as binding and enforce them in accordance with the rules of procedure of the territory where the award is relied upon. The Convention sets forth grounds for refusing enforcement in Article V, which are limited and exhaustively listed. These grounds include incapacity of parties, invalidity of the arbitration agreement, lack of proper notice, tribunal exceeding its authority, improper tribunal composition, award not yet binding or having been set aside, and violations of public policy.

Article II of the Convention addresses arbitration agreements themselves. It provides that each contracting state shall recognize an agreement in writing under which parties undertake to submit to arbitration all or any differences which have arisen or may arise between them concerning a defined legal relationship, whether contractual or not, concerning a subject matter capable of settlement by arbitration. When a court of a contracting state is seized of an action in a matter covered by an arbitration agreement, it shall refer the parties to arbitration at the request of one of the parties.

The Convention also incorporates the more-favorable-right provision in Article VII, which permits parties to rely on more liberal domestic laws or treaties for recognition and enforcement. This provision ensures that the Convention establishes a minimum standard rather than limiting the enforceability of arbitral awards [4].

UNCITRAL Model Law on International Commercial Arbitration

The United Nations Commission on International Trade Law developed the Model Law on International Commercial Arbitration in 1985, with significant amendments adopted in 2006 [5]. This legislative framework assists states in reforming and modernizing their laws on arbitral procedure to accommodate the particular features and needs of international commercial arbitration. The Model Law covers all stages of the arbitral process from the arbitration agreement through the composition and jurisdiction of the arbitral tribunal to the recognition and enforcement of the arbitral award.

The 2006 amendments modernized Article 7 regarding the form requirements for arbitration agreements to better conform with international contract practices. The revised version recognizes that arbitration agreements may take various forms beyond traditional signed documents. The amendments also introduced a new Chapter IV A establishing a more comprehensive legal regime dealing with interim measures in support of arbitration, addressing a significant gap in the original text.

The Model Law reflects worldwide consensus on key aspects of international arbitration practice and has been adopted by states across all regions and different legal and economic systems. Its widespread adoption has contributed to harmonization of arbitration laws internationally, making it easier for parties to predict the legal framework governing their arbitrations regardless of the seat chosen.

The ICSID Convention

The Convention on the Settlement of Investment Disputes between States and Nationals of Other States, commonly known as the ICSID Convention, was established in 1966 under the auspices of the World Bank [6]. This treaty created the International Centre for Settlement of Investment Disputes, which provides specialized facilities for arbitration and conciliation of investment disputes between contracting states and nationals of other contracting states. As of recent data, 158 states have ratified the ICSID Convention, making it one of the most widely accepted treaties governing investor-state disputes.

The ICSID Convention establishes a self-contained and autonomous system delocalized from domestic court procedures. This means that local courts do not intervene in the ICSID arbitration process. Under Article 53 of the Convention, awards rendered in ICSID Convention arbitrations are final and binding, and may not be set aside by the courts of any member state. The limited post-award remedies available are set out in the Convention itself through Articles 49 to 52, which provide for interpretation, revision, and annulment under strictly defined circumstances.

Article 54 of the ICSID Convention requires all member states, whether or not parties to a particular dispute, to recognize and enforce ICSID Convention monetary awards as if they were final judgments of their own courts. This robust enforcement mechanism distinguishes ICSID arbitration from other forms of international arbitration and provides investors with substantial confidence in the finality of awards. Once disputing parties consent to ICSID arbitration and unless they agree otherwise, they accept ICSID arbitration as the exclusive remedy under Article 26 of the Convention.

National Legislation: The United States Federal Arbitration Act

The Federal Arbitration Act, codified at 9 U.S.C. sections 1 through 16, governs arbitration agreements in contracts involving interstate commerce and applies in both federal and state courts [7]. Enacted in 1925 and codified in 1947, the FAA establishes the fundamental principle that arbitration agreements are valid, irrevocable, and enforceable, subject only to grounds applicable to contractual provisions generally.

Section 2 of the FAA declares that written arbitration provisions shall be valid, irrevocable, and enforceable, save upon such grounds as exist at law or in equity for the revocation of any contract. This provision embodies the federal policy favoring arbitration and limits the grounds for challenging arbitration agreements to general contract defenses such as fraud, duress, or unconscionability. Courts have consistently interpreted this provision as preempting state laws that disfavor arbitration agreements.

Chapter 2 of the FAA, comprising sections 201 through 208, implements the New York Convention in United States law. Section 201 provides that the Convention shall be enforced in United States courts in accordance with this chapter. Section 202 defines the scope of agreements and awards falling under the Convention, specifying that an agreement or award arising out of a legal relationship which is considered commercial falls under the Convention, except for relationships entirely between citizens of the United States unless that relationship involves property located abroad, envisages performance or enforcement abroad, or has some other reasonable relation with one or more foreign states.

The FAA provides procedures for compelling arbitration under Section 4, which allows a party aggrieved by another’s failure to arbitrate to petition any United States district court for an order directing that arbitration proceed. Section 9 addresses confirmation of arbitration awards, requiring courts to grant confirmation unless grounds exist under Section 10 for vacating the award. Section 10 limits the grounds for vacating awards to circumstances involving corruption, fraud, arbitrator misconduct, arbitrator exceeding powers, or failure to make a mutual, final, and definite award.

Institutional Arbitration Rules

ICC Arbitration Rules

The International Chamber of Commerce has developed comprehensive arbitration rules that entered into force on January 1, 2021 [8]. These rules define and regulate the management of cases received by the International Court of Arbitration. The ICC Court does not itself resolve disputes but administers the resolution of disputes by arbitral tribunals in accordance with its rules. The Court is the only body authorized to administer arbitrations under the ICC Rules, including scrutiny and approval of awards rendered in accordance with the rules.

Under the ICC Rules, the arbitral tribunal determines the language or languages of arbitration with due regard to all relevant circumstances including the language of the contract. The parties remain free to agree upon the rules of law to be applied by the tribunal to the merits of the dispute, and in the absence of such agreement, the tribunal shall apply the rules of law which it determines to be appropriate. When scrutinizing draft awards under Article 34, the ICC Court considers to the extent practicable the requirements of mandatory law at the place of arbitration.

UNCITRAL Arbitration Rules

The UNCITRAL Arbitration Rules provide a comprehensive set of procedural rules upon which parties may agree for the conduct of arbitral proceedings arising out of their commercial relationships [9]. These rules are widely used in both ad hoc arbitrations and administered arbitrations. Originally adopted in 1976, the rules were revised in 2010 to enhance efficiency while maintaining their original structure and spirit. The 2013 version incorporated the UNCITRAL Rules on Transparency for treaty-based investor-state arbitration.

The UNCITRAL Rules cover all aspects of the arbitral process, providing model arbitration clauses, setting out procedural rules regarding arbitrator appointments and conduct of proceedings, and establishing rules relating to the form, effect, and interpretation of awards. The rules include provisions dealing with multiple-party arbitration, joinder, liability, and procedures to object to experts appointed by the arbitral tribunal.

Regulation of Arbitral Proceedings

The regulation of international arbitration operates on multiple levels through party autonomy, institutional rules, and mandatory provisions of national law at the seat of arbitration. Parties enjoy considerable freedom to structure their arbitration proceedings, including selection of arbitrators, choice of procedural rules, determination of the seat and language of arbitration, and selection of applicable substantive law. However, this autonomy operates within boundaries established by the legal framework at the seat of arbitration and the requirements for enforceability under applicable treaties.

The concept of the seat of arbitration holds particular significance in this regulatory framework. The seat determines which national courts have supervisory jurisdiction over the arbitration and which national law governs the arbitral procedure as lex arbitri. Courts at the seat may exercise jurisdiction over applications to set aside awards, requests for interim measures, and challenges to arbitrator appointments. The selection of seat therefore constitutes a crucial decision with significant legal implications.

Arbitral institutions play an important regulatory role through their administrative functions. Institutions such as the ICC, ICSID, and others provide case management services, maintain panels of arbitrators, administer arbitrator appointments and challenges, fix arbitrator compensation, and scrutinize draft awards. The level of institutional involvement varies, with some institutions exercising extensive oversight and others providing primarily administrative support.

Contemporary Developments and Enforcement Mechanisms

Recent developments in international arbitration reflect efforts to enhance transparency, efficiency, and accessibility while maintaining confidentiality where appropriate. The 2022 amendments to the ICSID Arbitration Rules and the adoption of the UNCITRAL Rules on Transparency for treaty-based investor-state arbitration in 2013 exemplify the trend toward greater transparency in investment arbitration. These reforms respond to concerns about the legitimacy of investment arbitration and the need for public accountability when disputes involve matters of public interest.

The enforcement of international arbitral awards depends primarily on the New York Convention framework, supplemented by regional conventions and bilateral treaties. Under this framework, awards rendered in one contracting state are generally enforceable in other contracting states subject to the limited grounds for refusal specified in Article V. National courts play a crucial role in enforcement, but their review is limited to ensuring fundamental fairness and compliance with public policy rather than examining the merits of the dispute.

Challenges to enforcement typically involve arguments that the arbitration agreement was invalid, that proper notice was not provided, that the tribunal exceeded its jurisdiction, or that enforcement would violate public policy. Courts in different jurisdictions have developed varying approaches to these grounds, though there is a general trend toward narrow interpretation reflecting the pro-enforcement policy underlying the Convention.

Conclusion

International arbitration represents a sophisticated and mature system for resolving cross-border disputes, built on a foundation of multilateral treaties, institutional rules, and national legislation. The framework created by the New York Convention, UNCITRAL Model Law, ICSID Convention, and national statutes like the United States Federal Arbitration Act provides parties with confidence that their arbitration agreements will be enforced and that resulting awards will be recognized across borders. While challenges remain regarding issues such as costs, transparency, and consistency of outcomes, international arbitration continues to evolve through institutional reforms, legislative developments, and judicial interpretation that respond to the needs of the international business community.

References

[1] Program on Negotiation at Harvard Law School. (2025). International Arbitration: What it is and How it Works. Available at: https://www.pon.harvard.edu/daily/international-negotiation-daily/international-arbitration-what-it-is-and-how-it-works/ 

[2] JAMS. International Arbitration Rules. Available at: https://www.jamsadr.com/international-arbitration-rules 

[3] United Nations. (1958). Convention on the Recognition and Enforcement of Foreign Arbitral Awards. Available at: https://uncitral.un.org/en/texts/arbitration/conventions/foreign_arbitral_awards 

[4] New York Convention Guide. (1958). Introduction – Guide – NYCG 1958. Available at: https://newyorkconvention1958.org/index.php?lvl=cmspage&pageid=10&menu=674&opac_view=1 

[5] UNCITRAL. (1985, amended 2006). Model Law on International Commercial Arbitration. Available at: https://uncitral.un.org/en/texts/arbitration/modellaw/commercial_arbitration 

[6] ICSID. (1966). About ICSID. Available at: https://icsid.worldbank.org/About/ICSID 

[7] Legal Information Institute, Cornell Law School. U.S. Code: Title 9 — Arbitration. Available at: https://www.law.cornell.edu/uscode/text/9 

[8] ICC. (2021). 2021 Arbitration Rules. Available at: https://iccwbo.org/dispute-resolution/dispute-resolution-services/arbitration/rules-procedure/2021-arbitration-rules/ 

[9] UNCITRAL. Arbitration Rules. Available at: https://uncitral.un.org/en/texts/arbitration/contractualtexts/arbitration 

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