“All disputes, controversies or claims arising out of or related to this Contract or their breach, termination or invalidation shall be finally settled by arbitration, in accordance with the Arbitration Rules of the Arbitration Body of the Stockholm Chamber of Commerce.” If confidentiality is a concern, it is useful to insert a confidentiality clause, since the confidentiality approach may vary between different arbitral institutions and different jurisdictions. A clause dealing specifically with the arbitration procedure is advised instead of relying on more general confidentiality provisions applicable to the underlying contract. Several of the institutions offer standard formulas for such clauses14 You can also choose arbitration rules (such as SIAC rules) that contain explicit confidentiality clauses. However, difficulties may arise if the applicable law of the contract is distinguished from the seat of arbitration, for example English law, but the seat is Paris. Under these conditions, disputes may arise as to the applicable law in the arbitration agreement. To avoid such disputes, it is advisable either to include in the arbitration agreement an applicable legal provision (if you want the applicable law of the arbitration agreement to be in conformity with the law of the seat) or to extend the contractual provision of the applicable law so that it also covers the arbitration agreement (if you want the applicable law of the contract to apply). Parties to international commercial disputes often opt for arbitration, as the parties also wish, in the arbitration clause, to define the following: 4. .