INTERNATIONAL MED-AD AGREEMENT FOR CONSTRUCTION DISPUTES

© Daniel Atkinson 2002 7 April 2002

 

DISCLAIMER:

Parties should seek legal advice before entering into the Med-Ad Agreement and/or satisfy themselves that the Med-Ad Agreement is appropriate for resolution of their differences.

 

THIS AGREEMENT is made on .....…...….day of.......……..........………year…………….
between (the First Party) ......................................................................................
of: ......................................................................................
and (the Second Party) ......................................................................................
of: ......................................................................................
(the "Parties")
and: ......................................................................................
of: ......................................................................................
(the "Med-Adjudicator")

WHEREAS

A. Disputes and differences under a contract dated ................... (the "Contract") have arisen between the Parties in connection to works known as:
...................................................................................................................................
(the "Works")
B. The differences and disputes which are referred to this Med-Adjudication are:
...................................................................................................................................
...................................................................................................................................
(the "Dispute")
C. The Parties may, at any time before the issue of a notice of intention to refer the Dispute or any part of the Dispute to adjudication, agree that additional differences and disputes shall be added to this Med-Adjudication.  If the agreement is recorded in writing signed by the Representatives and the Med-Adjudicator, and if the said written agreement specifies the additional differences and disputes, the meaning of Dispute in this Med-Adjudication shall be modified and amended to include the specified additional differences and disputes.
D. The Parties wish to resolve the Dispute and enter into this Med-Adjudication in good faith and in order to achieve settlement of all or part of the Dispute by written agreement and to resolve any remaining part of the Dispute not settled by written agreement, by the decision of the Med-Adjudicator acting as an adjudicator.
E. Either Party may give notice at any time of its intention to refer the Dispute, any part of the Dispute or any dispute arising under the Contract to adjudication whether as part of this Agreement or otherwise.

In order to promote communication between the Parties and to facilitate resolution of the Dispute

IT IS NOW AGREED as follows:

Representatives and Participants

1. Each Party is represented in this Med-Adjudication by:
The First Party:  ..................................................................................................................
The Second Party:  ..................................................................................................................
(Each the Party’s “Representative” and jointly the “Representatives” )
2. In addition to the Representatives, the following will be present at and/or participate in the Med-Adjudication on behalf of each of the Parties:
The First Party:  ..................................................................................................................
The Second Party:  ..................................................................................................................
(Each the Party’s “Participant” and jointly the “Participants” )
3. Each Party’s Representative acts for and on behalf and has the authority to settle the Dispute on behalf of the Party he/she represents.
4. Each Party’s Representative agrees to be bound by the provisions of this Agreement and does so on its own behalf, on behalf of the Party he/she represents and on behalf of that Party’s Participant(s).
5. A Party shall notify both the other Party and the Med-Adjudicator immediately on any change to the above.

Place of Med-Adjudication

6. The place of the Med-Adjudication is:
.................................................................................................................................

Reckoning of Days

7. Where under this Agreement an act is required to be done within a specified period of days or from a specified date, the period shall begin immediately after that date. Where the period would include a day which is a day which under applicable legislation of the place of the Med-Adjudication is a bank holiday (a “Public Holiday”) that day shall be excluded.

Replacement of Med-Adjudicator

8. If the Med-Adjudicator becomes ill or becomes unavailable for some other cause and is thus unable to act on the Dispute referred to him he shall immediately give notice to the Parties to such effect, so far as he is capable of so doing.
9. If the Med-Adjudicator dies or becomes ill or is unavailable for some other cause and is thus unable to act on the Dispute referred to him, the Parties may either agree upon an individual to replace the Med-Adjudicator or the First Party shall nominate a replacement from those named or referred to in a list in the Contract as replacement Med-Adjudicator to act on the Dispute. The replacement Med-Adjudicator shall decide not only that dispute or difference but all further disputes or differences referred in accordance with this Agreement, subject always to further replacement in accordance with this Clause. Provided that
  1. any agreement by the Parties on the appointment of a replacement Med-Adjudicator must be reached with the object of securing the appointment of, and the referral of the dispute or difference to, the replacement Med-Adjudicator within 7 days of the Parties first becoming aware that the Med-Adjudicator is unable to act;
  2. any nomination by the First Party must be made with the object of securing appointment of, and the referral of the dispute or difference to, the replacement Med-Adjudicator within 7 days of the Parties first becoming aware that the Med-Adjudicator is unable to act;
  3. upon selection of the replacement Med-Adjudicator the Parties shall thereupon execute with the replacement Med-Adjudicator a revised Med-Adjudication Agreement in the form of this Agreement.

Place of Mediation Meeting

10. The Mediation Meeting shall take place at:
.................................................................................................................................

The Conduct of the Mediation

11. Each Party shall within two days of the appointment of the Med-Adjudicator submit to the Med-Adjudicator and to the other Party a concise summary (the “Summary”) of its view of the Dispute and all relevant documents to which the Summary refers.
12. The Med-Adjudicator and the Parties shall agree the date and place for the Mediation Meeting. The Parties shall be responsible for the costs of the place of mediation including but not limited to room charges, communication and other facilities and refreshments.
13. Each Party shall, in advance of the meeting, inform the Med-Adjudicator and the other Party in writing of the name of its representative for the mediation part of the Med-Adjudication (the "Mediation"), who shall have full authority to act on behalf of that Party and the names of any other persons who will attend the Mediation Meeting.
14. Before the date of the Mediation Meeting, the Mediator shall read each Summary.
15. At the place of the Mediation Meeting, the Mediator shall chair and determine the procedure of the Mediation.

Status of Information in the Mediation

16. The Parties understand and agree that the process of Mediation adopted in this Med-Adjudication is not confidential as between the Med-Adjudicator and the Parties.  Although this Mediation process is adopted to achieve a settlement of the Dispute by written agreement, the process insofar as and to the extent that it involves the Med-Adjudicator is not considered settlement negotiations for any purposes.
17. The Med-Adjudicator, the Parties, the Representatives and the Participants understand and agree that all the following will not be kept confidential from the Parties and may be referred to by the Med-Adjudicator if required to act as adjudicator in any dispute whether under this Agreement, relating to the Dispute or otherwise arising out of the Works 
  1. all communications and information (whether given orally, in writing or otherwise) disclosed to the Med-Adjudicator for, during, or as a result of this Mediation, and
  2. all discussions between the Med-Adjudicator and either individually or together the Parties, the Representatives and the Participants in the course of this Mediation, and
  3. all consultations by the Med-Adjudicator in relation to the Mediation, and
  4. all the Med-Adjudicator's oral or written communications with the Parties, Participants and Representatives in this Mediation in a continuing effort to resolve the Dispute.

(the "Mediation Information")

18. Any Mediation Information shall not be privileged and shall be admissible as evidence and is not prevented from being produced in any litigation, arbitration, adjudication or other proceedings whether relating to the Dispute or otherwise arising out of the Works, solely by reason of its introduction or use in this Mediation.
19. If one Party discloses information only to the Med-Adjudicator, the Med-Adjudicator shall give to the absent Party a complete and accurate account of what has taken place.  The Party disclosing information shall provide copies of any written information to the absent Party.

Investigation and Enquiries During Mediation

20. The Parties have appointed the Med-Adjudicator to act in the Mediation to discuss the respective positions of the Parties on each of the issues constituting the Dispute and to provide them with his written view on each issue (together the "Views").  The Med-Adjudicator shall state with the issue of the last View that he has given a View on all the issues in the Dispute and shall issue the Views within 10 days of the date of this Agreement.  The aim of the Parties in adopting this Mediation process is to allow the Parties thereafter to agree and settle between them as many of the issues as possible.  Other than the Views, the Med-Adjudicator shall not issue to the Parties, Representatives or the Participants either orally or in writing a report, assessment, evaluation, decision, recommendation, opinion or finding of any kind concerning the issues, this Mediation or the Dispute.
21. The Med-Adjudicator as mediator shall meet with the appointed representatives of the Parties and discuss the respective positions of the Parties on each issue.  The Med-Adjudicator shall then decide how to proceed in the Mediation on each issue including any of the following:
  1. request the Parties to provide evidence and/or argument in respect of any issue;
  2. indicate to the Parties that he considers that he is able to make a concluded view on an issue and invite the Parties to state whether there are particular matters which they wish him to consider before issuing the concluded view;
  3. indicate to the Parties that he considers he is able to make a provisional view on an issue, stating the matters which remain to be resolved and whether they involve contractual/legal issues and/or factual issues and invite the Parties to state whether there are particular matters which they wish him to consider before issuing the provisional view;
  4. issue the Views stating for each issue whether it is a Concluded View or a Provisional View and stating the facts and law he has based his view upon and in the case of a provisional view the matters which remain to be resolved and whether they involve contractual/legal issues and/or factual issues.
22. The Parties agree that the Views shall have no legal effect and are not binding on the Parties nor the Med-Adjudicator except and to the extent that they are incorporated in the Settlement Agreement or in the decision of the Med-Adjudicator as adjudicator.  The Parties understand and agree that any Concluded View issued by the Med-Adjudicator during this Mediation may be incorporated into the decision of the Med-Adjudicator as adjudicator and that when preparing his decision the Med-Adjudicator has the right to modify and/or elaborate any such Concluded View in the light of the totality of the evidence and the submissions of the Parties in the Adjudication.
23. Other than the Views, neither the Med-Adjudicator, the Parties, the Representatives nor the Participants may submit either orally or in writing a report, assessment, evaluation, decision, recommendation, opinion or finding of any kind of the Med-Adjudicator concerning this Mediation to any court, arbitrator, adjudicator or other legal tribunal whether relating to the Dispute or otherwise arising out of the Works.

The Settlement Agreement

24. Any settlement, of the whole or of part of the Dispute, reached in this Mediation will not be legally binding until it has been reduced to writing and signed by, or on behalf of, the Parties.
25. The Med-Adjudicator shall, if so requested by the Parties, assist them to prepare the settlement agreement, but the Parties shall have the agreement independently reviewed by its own legal advisors before executing the settlement agreement.
26. If the Med-Adjudicator signs the settlement agreement, he/she shall only sign as a witness and not as a party to the settlement agreement.

Termination of Mediation

27. This Mediation may be terminated at any time without any adverse reflection or comment by the Parties and/or the Med-Adjudicator in any subsequent adjudication.
28. This Mediation will terminate when:
  1. a Party informs the Med-Adjudicator as mediator that it withdraws from the Mediation; or
  2. a period of 10 calendar days after the date of this Agreement: or
  3. the Med-Adjudicator has issued a View for each of the issues in the Dispute and for this purpose the Parties agree that a statement by the Med-Adjudicator on issue of a View that he has done so is conclusive; or
  4. a written settlement agreement is executed which fully resolves the Dispute; or
  5. the Med-Adjudicator decides at his/her sole discretion that continuing the Mediation is unlikely to achieve the objective of being cost effective: or
  6. the Med-Adjudicator decides at his/her sole discretion that one Party is not acting in good faith; or
  7. after the date of this Agreement a Party issues a notice of intention to refer a dispute under the Contract to adjudication.

Commencement of Adjudication

29. The Parties understand and agree that the issue of the Summary by each Party is not a notice of intention to commence adjudication nor a submission in adjudication and that a separate notice is required to commence adjudication.
30. The Parties agree that the Med-Adjudicator shall act as adjudicator for the Dispute or for any part of the Dispute and shall substitute any person previously named in the Contract. 
31. The Parties agree that the Dispute or any part of the Dispute may be resolved by adjudication in this Med-Adjudication and if the Dispute comprises more than one dispute consent to it being decided in one adjudication.

Adjudication Procedure

32. The Party which requires the Dispute or part of the Dispute to be referred to adjudication shall serve the Notice of Intention to Refer on the other Party by pre-paid post, addressed to the other Party’s address in this Agreement.
33. Within 7 days from the date of the Notice of Intention to Refer the Party giving the notice of intention shall refer the dispute or difference to the Med-Adjudicator for his decision as adjudicator (the “Referral”). The Referral shall include particulars of the dispute or difference together with a summary of the contentions on which the Party relies, a statement of the relief or remedy that is sought and any material the Party wishes the Med-Adjudicator to consider as adjudicator. The Referral shall be copied simultaneously to the other Party.
34. The referral by a Party to the Med-Adjudicator as adjudicator and the copies thereof to be provided to the other Party shall be given by actual delivery or by FAX or by registered post or recorded delivery. If given by FAX then, for record purposes, the Referral must forthwith be sent by first class post or given by actual delivery. If sent by register post or recorded delivery the Referral shall subject to proof to the contrary, be deemed to have been received 48 hours after the date of posting subject to the exclusion of any Public Holiday.
35. The Med-Adjudicator shall immediately upon receipt of the Referral confirm the date of that receipt to the Parties.
36. The Party not making the Referral may, by the same means stated in Article 34 of this Agreement, send to the Med-Adjudicator within 7 days of the date of the Referral with a copy to the other Party, a written statement of the contentions on which he relies and any material he wishes the Med-Adjudicator to consider.
37. The Med-Adjudicator shall within 28 days of his receipt of the Referral reach his decision as adjudicator and forthwith send that decision in writing to the Parties.
Provided that the Party who has made the Referral may consent to allowing the Med-Adjudicator to extend the period of 28 days by up to 14 days; and that by agreement between the Parties after the Referral has been made a longer period than 28 days may be notified jointly by the Parties to the Med-Adjudicator within which to reach his decision as adjudicator.
38. The Med-Adjudicator shall give reasons for his decision as adjudicator.
39. The decision of the Med-Adjudicator as adjudicator (the "Decision") shall be binding on the Parties and the Parties shall comply with the Decision and shall ensure that the Decision of the Med-Adjudicator is given full effect as conclusive and binding under the terms of the Contract until the dispute is finally determined by legal proceedings, by arbitration (if the Contract provides for arbitration or the parties otherwise agree to arbitration) or by agreement.
40. If either Party does not comply with the Decision the other Party shall be entitled to take legal proceedings to secure such compliance.
41. Any failure by either Party to comply with any requirement of the Med-Adjudicator under Article 42 or with any provision in or requirement under this Agreement shall not invalidate the Decision.
42. In reaching his decision as adjudicator the Med-Adjudicator shall act impartially, set his own procedure and at his absolute discretion may take the initiative in ascertaining the facts and the law as he considers necessary in respect of the Referral which may include the following:
  1. using his own knowledge and/or experience;
  2. determining whether a contract exists between the Parties;
  3. opening up, reviewing and revising any certificate, opinion, decision, requirement or notice issued given or made under any contract between the Parties as if no such certificate, opinion, decision, requirement or notice had been issued given or made;
  4. requiring from the Parties further information than that contained in the Referral or in any written statement provided by the Parties including the results of any tests that have been made or of any opening up;
  5. visiting the site of the works or any workshop where work is being or has been prepared;
  6. obtaining such information as he considers necessary from any employee or representative of the Parties provided that before obtaining information from an employee of a Party he has given prior notice to that Party;
  7. obtaining from others such information and advice as he considers necessary on technical and on legal matters subject to giving prior notice to the Parties together with a statement or estimate of the cost involved;
  8. having regard to any term of any contract between the Parties relating to the payment of interest deciding the circumstances in which or the period for which a simple rate of interest shall be paid.

Status of Adjudicator's Decision

43. The Parties agree and acknowledge that the Med-Adjudicator when acting as adjudicator does not act as an arbitrator and the reference to adjudication is not a submission to arbitration within the meaning of the relevant arbitration legislation of the place of Med-Adjudication.  The Parties agree and acknowledge that the Decision is a decision made under the Contract as part of the contractual machinery and shall be conclusive evidence only if and to the extent that the Parties expressly agree in writing.

Termination of the Adjudication

44. The Parties jointly may:
  1. terminate this Agreement at any time on written notice to the Med-Adjudicator;
  2. terminate an adjudication part of this Med-Adjudication at any time and immediately give written notice to the Med-Adjudicator thereof.

Following such termination the Parties shall, subject to Article 45, pay the Med-Adjudicator his fee or any balance thereof and his expenses reasonably incurred prior to the termination.

45. When the decision of the Parties to terminate the Adjudication Agreement under Article 43 is because of a failure by the Med-Adjudicator to give his decision on the dispute or difference within the time-scales in this Agreement or at all, the Med-Adjudicator shall not be entitled to recover from the Parties his fee and expenses for the adjudication.

Interpretation

46. This Agreement shall be interpreted and applied in the manner most conducive to the efficient conduct of the proceedings with the primary objective of achieving a settlement of the Dispute by written agreement between the Parties as quickly as possible.

Other Proceedings

47. The Med-Adjudicator shall not be called as a witness at any litigation, arbitration, adjudication or other proceedings whether relating to the Dispute or otherwise arising out of the Works.
48. The Med-Adjudicator shall not represent and/or advise any Party or any Representative or any Participant in any proceedings whether relating to the Dispute or otherwise arising out of the Works.
49. Unless agreed by the Parties, the Med-Adjudicator shall not be appointed arbitrator in any proceedings whether relating to the Dispute or otherwise arising out of the Works.
50. Any litigation, arbitration or adjudication in relation to the Dispute may be commenced or continued notwithstanding this Med-Adjudication unless the Parties agree otherwise.

Confidentiality

51. The Parties and the Med-Adjudicator shall at all times maintain the confidentiality of the Med-Adjudication subject to consent of the other Parties which will not be unreasonably withheld.

Med-Adjudicator’s Fees and Legal Expenses

52. Each Party shall be responsible for payment of the fees and expenses of the Med-Adjudicator as follows:
  1. when acting as mediator, each party is responsible in equal share
  2. when acting as adjudicator, each party is responsible for the share as decided by the Med-Adjudicator in his Decision

Save that the Parties are jointly and severally liable for the whole of said fees and expenses. If any Party fails to make the payment due from him, the other Party may pay the sum to the Med-Adjudicator and recover the amount from the defaulting Party as a debt due. Payment of the said fees and expenses will be made in accordance with the attached Fee Schedule.

53. Each Party shall bear its own costs and expenses of its participation in this Mediation.

Law and Jurisdiction

54. This Agreement shall be governed by, construed and take effect in accordance with the law of the Contract.
55. The Med-Adjudicator does not act as as advocate for any Party. The Parties agree and accept that the Med-Adjudicator's statements, including the Views, are not legal advice to any Party.
56. The Med-Adjudicator shall not be liable to the Parties or any person claiming through them for any matter arising out of or in connection with this Med-Adjudication or the way in which it is or has been conducted, and the Parties shall not bring or allow to be brought on its behalf any such claims against the Med-Adjudicator.
Signed on behalf of
First Party
Name: ......................................................................................
Signature: ......................................................................................
Date: ......................................................................................
Second Party
Name: ......................................................................................
Signature: ......................................................................................
Date: ......................................................................................
Med-Adjudicator
Name: ......................................................................................
Signature: ......................................................................................
Date: ......................................................................................