The purpose of this guide is to provide in-house counsel and other party representatives, such as managers and government officials, with a practical toolkit for making decisions on how to conduct an arbitration in a time- and cost-effective manner, having regard to the complexity and value of the dispute. The guide can also assist outside counsel in working with party representatives to that effect.

Reflecting the ICC's continuing efforts to provide arbitration users with means to ensure that arbitral proceedings are conducted effectively, the guide focuses on time and cost issues in the management of arbitration. While strategic considerations are of great importance in any arbitration and will have a significant impact on its management, they tend to be case-specific and are beyond the scope of this guide.

While the guide was conceived with the ICC Rules of Arbitration in mind, most of its contents, as well as the dynamic generated by it, can be used in any arbitration. The guide can be useful for both large and small cases.

INTRODUCTION


SETTLEMENT CONSIDERATIONS


CASE MANAGEMENT CONFERENCE


TOPIC SHEETS


Topic Sheet 1: Request for Arbitration

Topic Sheet 2: Answer and Counterclaims

Topic Sheet 3: Multiparty Arbitration

Topic Sheet 4: Early Determination of Issues

Topic Sheet 5: Rounds of Written Submissions

Topic Sheet 6: Document Production

Topic Sheet 7: Need for Fact Witnesses

Topic Sheet 8: Fact Witness Statements

Topic Sheet 9: Expert Witnesses (pre-hearing issues)

Topic Sheet 10: Hearing on the Merits (including witness issues)

Topic Sheet 11: Post-hearing Briefs