The moderator, Ms Julie Raneda (Schellenberg Wittner), started the discussion by introducing the speakers and the context for the webinar - Switzerland is perceived to be a neutral venue, has many experienced arbitrators, is one of the places of choice for ICC arbitration and also one of the top three centres for international arbitration. Singapore, likewise, is seen to be a neutral venue, has many outstanding practitioners, is the seat of the most successful arbitration centre in Asia, has a robust legislation and strong legal framework supporting arbitration as well as an international arbitration hub. There are therefore lessons that each can learn from the other.
The speakers spoke on four aspects of arbitration law and practice in the 2 jurisdictions: (1) recent reforms in each country, (2) conflicts of law and the governing law of the arbitration agreement, (3) admissibility and jurisdiction, and (4) public policy.
Ms Anya George (Schellenberg Wittmer) began by going through the recent arbitration-related reforms in Switzerland to Chapter 12 of the Swiss Private International Law Act in January 2021 and the Swiss Arbitration Centre/ Swiss Rules in June 2021. Prof Darius Chan then spoke on the recent reforms in Singapore arbitration. Dr Matthew Secomb (White & Case) summed up his observation that where the jurisdiction has a strong arbitration framework like both Switzerland and Singapore, changes are usually small for keeping up with time and technological changes. Dr Darius observed that in Singapore, the government is always quick to make changes where such changes assist Singapore’s competitiveness as an arbitration centre. The speakers also reviewed key issues on conflicts of law, and also the question whether public policy should be an element in setting aside the arbitration award.
The speakers took some questions during the Q&A before closing the webinar with a note of thanks to the speakers and all present.
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Khoo Jing Ling Gillian - Wii Pte Ltd