Model Documents

The following clause is recommended:

"For the purpose of resolution of each and any dispute, claim, controversy, and disagreement that has arisen or might arise from the present agreement, or any further agreements resulting from the same, the parties shall – or a party shall – file a request for mediation with the NAI Secretariat in accordance with the CAfA Mediation Rules, consisting of the Mediation Rules of the Netherlands Arbitration Institute supplemented and modified by the AiA/NAI Adjunct Mediation Rules."


The mediation agreement is concluded between the parties and the mediator during the first meeting.