'1. Notifications and communications in this arbitration to the parties shall be validly made at the addresses of counsel to Claimants and Respondent indicated in Sections 1.1 and 1.2 of the Terms of Reference.

Notifications, communications and submissions between the Arbitral Tribunal and the parties can be made by registered mail, courier service or telefax. However, faxes require confirmation copies by registered mail or courier service. The use of e-mail requires specific agreement.

The parties shall send their notifications, communications and submissions directly to each member of the Arbitral Tribunal and simultaneously send a full copy to the other party and to the ICC Secretariat.

2. In the parties' written submissions to the Arbitral Tribunal, the factual and legal allegations shall be numbered and expressed with appropriate precision. The other party's determination shall contain, at a minimum, a reply, allegation by allegation.

3. The parties shall indicate in their written submissions the nature of evidence relied upon (exhibit(s), witness testimony, expert opinion, specifically designated documents to be produced by the other party, etc.) by providing, with reasonable specificity, references to the exhibits and witness statements submitted in support of their allegations.

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7. Any individual, including parties and their representatives, may be a witness.

8. Each party shall notify the other of witnesses whom they intend to testify in the proceedings. The parties shall file written witness statements of each such witness. The Arbitral Tribunal will decide on issues such as possible filing of rebuttal witness statements or the refusal of witnesses to cooperate.

9. A party may request the other party to produce a person as a witness to testify in the proceedings and shall notify the other party of the purpose of such testimony. Each party shall cooperate in producing such witnesses. Should an issue arise, the Arbitral Tribunal will rule on the relevance of such person's appearance as a witness in light of the stated purpose.

10. A witness duly summoned, who does not appear at the hearing of the Arbitral Tribunal scheduled to hear his testimony, shall, in principle, only be summoned a second time on timely presentation of a valid excuse.

Where a witness should ultimately not be able to attend for a valid reason, the Arbitral Tribunal shall in principle not be entitled to consider his written statement, except if extraordinary circumstances so warrant. In such event the Arbitral Tribunal shall hear the parties and decide by taking, however, into account all relevant circumstances, including the parties' legitimate interests.

The parties shall name the opposing party's witnesses whom they intend to cross-examine. Where a party does not intend to cross-examine a specific witness of its opposing party, it is deemed to accept the contents of the witness' written statement and the witness need not be summoned to appear, unless his hearing is requested by the Arbitral Tribunal.

The parties shall be responsible for ensuring the presence of the witnesses at the hearing. Upon request, the Arbitral Tribunal will assist the parties with respect to witnesses not under their control.

The costs of a witness appearance shall be borne by the party proposing his testimony until the Arbitral Tribunal shall decide, in its final award, on the respective allocation of such costs.

11. Unless witness conferencing is provided for, the procedure for the witness hearings shall be as follows:

Every witness called shall first of all be invited to confirm or deny, as the case may be, his written statement.

His written statement shall, in principle, be considered his direct testimony. He shall then be cross-examined by opposing counsel, followed by re-direct examination by counsel of the party presenting the witness.

The Arbitral Tribunal may examine the witnesses at any time, either before, during or after their examination or cross-examination by the counsel of one of the parties.

The witness examinations shall be in English, with the exception that witness depositions may be made in another language if the arbitrators are satisfied that the witness cannot give evidence in English. If witness depositions are thus made in a language other than English they shall, in principle, be simultaneously translated.

The Arbitral Tribunal shall appoint court reporters to take verbatim transcripts of witness hearings.

12. The Arbitral Tribunal shall, at all times, have a complete right of control over the procedure in relation to the examination of a witness, including the right to limit or refuse the right of a party to examine a witness when it considers that the factual allegation(s) on which the witness is intended to depose is sufficiently proven by exhibits or other witnesses or that the particular witness deposition as such is irrelevant.

13. The parties may submit expert opinions and offer the testimony of their expert witnesses. Where appropriate, Rules 8 - 12 are applicable to expert witnesses.

14. The Arbitral Tribunal may appoint one or more experts on its own initiative, or at the request of a party. Before appointing an expert, the Arbitral Tribunal shall allow the parties to be heard on the issue.

The Arbitral Tribunal shall cooperate with the parties in respect of defining the expert's mission and of drafting the questions to the expert.

The expert appointed by the Arbitral Tribunal shall in principle submit a written report and, at the request of one of the parties or of the Arbitral Tribunal, may be asked to appear at a hearing to be heard personally.

15. The Arbitral Tribunal shall set the time limits and extend them as necessary.

The extension of deadlines shall only be granted exceptionally and provided that a request is submitted immediately after the event preventing the party from complying with the deadline.

Except where a request for extension is entirely dismissed, the Chairman of the Arbitral Tribunal, acting alone, will be authorized to extend any procedural time limit set to the parties during the course of the arbitration proceedings.'