i) Investors and their Investments shall not, either prior to or after the establishment of an Investment, offer, promise, or give any undue pecuniary advantage, gratification or gift whatsoever, whether directly or indirectly, to a public servant or official of a Party as an inducement or reward for doing or forbearing to do any official act or obtain or maintain other improper advantage nor shall be complicit in inciting, aiding, abetting, or conspiring to commit such acts.

(iii) Investors and their Investments shall comply with the provisions of Law of the Parties concerning taxation,

(iv) An Investor shall provide such information as required by the Law of the Parties concerning the Investment.

Article 13. Corporate Social Responsibility

Investors and their Enterprises operating within the Territory of each Party shall endeavour to voluntarily incorporate internationally recognized standards of corporate social responsibility in their practices and internal policies, such as statements of principle that have been endorsed or are supported by the Parties. These principles may address issues such as labour, the environment, human rights, community relations and anti-corruption.

Chapter IV. Settlement of Disputes between an Investor and a Party

Article 14. Scope and Definitions

14.1 Without prejudice to the rights and obligations of the Parties under Chapter V, this Chapter establishes a mechanism for the settlement of disputes between an Investor and a Defending Party.

14.2 This Chapter shall only apply to a dispute between a Party and an Investor of the other Party with respect to its Investment, arising out of an alleged breach of an obligation of a Party under Chapter II of this Treaty, other than the obligation under Articles 10(Entry and Sojourn of Personnel), and 11(Transparency) of this Treaty.

14.3 A Tribunal constituted under this Chapter shall only decide claims in respect of a breach of this Treaty as set out in Chapter II, except under Articles 10 (Entry and Sojourn of Personnel) and 11 (Transparency), as opposed to any other disputes arising solely from an alleged breach of a contract between a Party and an Investor. Such disputes shall only be resolved in accordance with the dispute resolution provisions set out in the relevant contract.

14.4 An Investor shall not submit a claim to arbitration under this Chapter if the Investment or the Investor with respect to its Investment has been finally judicially determined to have been made through fraud, fraudulent misrepresentation, concealment, corruption, money laundering, round tripping or conduct amounting to an abuse of process or similar illegal mechanisms as provided under due process of law. Where proceedings have already been commenced under this Chapter, the Tribunal constituted under this Chapter shall suspend any proceedings pending the decision of the competent court(s) regarding above mentioned irregularities.

14.5 Where any proceedings are brought or ongoing against an Investor connected to the Investment, or against the Investment itself, in respect of any allegation of fraud, fraudulent misrepresentation, concealment, corruption, money laundering, round tripping or conduct amounting to an abuse of process or similar illegal mechanisms as provided under due process of law, any arbitral proceedings under this Chapter shall be suspended pending the decision of the competent court(s) regarding above mentioned irregularities.

14.6 In addition to other limits on its jurisdiction, a Tribunal constituted under this Chapter shall not have the jurisdiction to:

(i) review the merits of a decision made by a competent judicial authority of the Territory of the Parties; or

(ii) accept jurisdiction over any claim that is or has been subject of an arbitration under Chapter V.

14.7 A dispute between an Investor and a Party shall proceed sequentially in accordance with this Chapter.

14.8 For the purposes of this Chapter:

(i) "Defending Party" means a Party against which a claim is made under this Chapter.

(ii) "disputing party" means a Defending Party or a disputing Investor and "disputing parties" means both of them.

(iii) "disputing Investor" means an Investor of a Party that makes a claim against the other Party under this Chapter either on its own behalf or on behalf of the locally established Enterprise through which an Investment is made.

(iv) "ICSID" means the International Centre for Settlement of Investment Disputes.

(v) "ICSID Additional Facility Rules" means the Rules Governing the Additional Facility for the Administration of Proceedings by the Secretariat of the International Centre for Settlement of Investment Dispute.

(vi) "ICSID Convention" means the Convention on the Settlement of Investment Disputes between States and Nationals of other States, done at Washington on 18 March 1965.

(vii) "New York Convention" means the United Nations Convention on the Recognition and Enforcement of Foreign Arbitral Awards, done at New York on 10 June 1958.

(viii) "Non-disputing Party" means the Party to this Treaty which is not the Defending Party.

(ix) "UNCITRAL Arbitration Rules" means the arbitration rules of the United Nations Commission on International Trade Law.

Article 15. Proceedings Under Different International Agreements

15.1 Where claims are brought pursuant to this Chapter and another international agreement and:

(a) there is a potential for overlapping compensation; or

(b) the other international claim could have a significant impact on the resolution of the claim brought pursuant to this Chapter,

15.2 A Tribunal constituted under this Chapter shall, as soon as possible after hearing the disputing parties, stay its proceedings or otherwise ensure that proceedings brought pursuant to the other international agreement are taken into account in its decision, order or award.

Article 16. Third Party Funding

Third Party funding of the Investor in case of dispute is not permitted.

Article 17. Conditions Precedent to Submission of a Claim to Arbitration

17.1 In respect of a claim that the Defending Party has breached an obligation under Chapter II, other than an obligation under Articles 10 (Entry and Sojourn of Personnel) or 11 (Transparency), a disputing Investor must first pursue available local remedies through submitting its claim before the competent domestic courts or administrative/regulatory bodies of the Defending Party in accordance with the applicable Laws and regulations in respect of the same measure or similar factual matters for which a breach of this Treaty is claimed. Such a claim before the relevant domestic courts or administrative bodies of the Defending Party must be submitted within one (1) year from the date on which the Investor first acquired, or should have first acquired, knowledge of the measure(s) in question and knowledge that the Investment, or the Investor with respect to its Investment, had incurred loss or damage as a result of the measure(s)("Disputing Investor's Knowledge Date").

The date of filing of the first claim before the relevant domestic courts or administrative bodies of the Defending Party shall be referred to as the "Date of Local Claim".

For the avoidance of doubt, the aforementioned one (1) year limitation period shall only be relevant to an Investor's access to rights or recourse under this Treaty and shall be without prejudice to any other statutory limitation period under applicable Law that may apply to any other claim that the Investor may be entitled to bring.

In demonstrating compliance with the obligation to pursue local remedies, the Investor shall not assert that the obligation to pursue local remedies does not apply or has been met on the basis that the claim under this Treaty is by or against a different party or in respect of a different cause of action.

The requirement to pursue local remedies shall not be applicable, if the disputing Investor or the locally established Enterprise can demonstrate that there are no available domestic legal remedies capable of reasonably providing any relief in respect of the same measure or similar factual matters for which a breach of this Treaty is claimed by the disputing Investor.

For the purposes of this Article, local remedies shall be deemed to have been pursued for the purposes of being entitled to submit notice of dispute ("Notice of Dispute"), if no resolution that is satisfactory to the disputing Investor has been reached after pursuing for at least a period of three years from the disputing Investor's Knowledge Date (or lesser period where available local remedies have been exhausted within such period), regardless of any pending appeal or other ongoing proceedings in the domestic courts or administrative bodies of the Defending Party. In such case, the disputing Investor shall have the absolute right under this Chapter to transmit a Notice of Dispute to the Defending Party.

17.2 The Notice of Dispute shall:

(a) specify the name and address of the disputing Investor or the Enterprise, where applicable;

(b) set out the factual basis of the claim, including the measures at issue;

(c) specify the provisions of the Treaty alleged to have been breached and any other relevant provisions;

(d) demonstrate compliance with Article 17.1 and 17.2, where applicable;

(e) specify the relief sought and the approximate amount of damages claimed; and furnish evidence establishing that the disputing Investor is an Investor of the Non-disputing Party.

(f) specify complete details of the interest in Investment including ownership, control and economic rights for which the Investor claims to have suffered loss or damage as a result of the alleged breach, at all levels, over the period of time since Investment was made including nature and date of creation of such interest. A disputing Investor shall be deemed to have disclosed all details and should the Defending Party identify any material undisclosed information at a later point in time, the Defending Party shall withdraw the consent to Arbitration as under Article 19(Consent to Arbitration) and the arbitration proceedings shall be terminated.

17.3 For no less than six (6) months after receipt of the Notice of Dispute, the disputing parties shall use their best efforts to try to resolve the dispute amicably through meaningful consultation, negotiation or other third party procedures.

17.4 In the event that the disputing parties cannot settle the dispute amicably as stipulated in Article 17.3, a disputing Investor may submit a claim to arbitration pursuant to this Treaty, but only if the following additional conditions are satisfied:

(i) not more than five (5) years have elapsed from the date on which the dis- puting Investor first acquired, or should have first acquired, knowledge of the measure in question and knowledge that the disputing Investor with re- spect to its Investment, had incurred loss or damage as a result; or

(ii) where applicable, not more than twelve (12) months have elapsed from the conclusion of domestic proceedings pursuant to 17.1.

(iii) the disputing Investor or the locally established Enterprise have waived their right to initiate or continue before any administrative tribunal or court under the Law of either Party, or other dispute settlement procedures, any proceedings with respect to the measure of the Defending Party that is alleged to be a breach referred to in Article 14.2.

(iv) In case of indirect Investment, a disputing Investor may submit a claim under Chapter IV only if both the disputing Investor and the legal entity of any other territory through which the Investment has been made, waive their right to initiate or continue any proceeding, including under any other bilateral or multilateral investment treaty, with respect to the measure of the Defending Party that is alleged to be a breach referred to in Article 14.2. Such waivers shall be provided in writing to the Defending Party by the disputing Investor and the legal entity of any other territory through which the Investment has been made.

(v) where the claim submitted by the disputing Investor is for loss or damage to an interest in an Enterprise established in the Territory of the other Party that is a juridical person that the disputing Investor owns or controls, that Enterprise has waived its right to initiate or continue before any administrative tribunal or court under the Law of any Party, or other dispute settlement procedures, any proceedings with respect to the measure of the Defending Party that is alleged to be a breach referred to in Article 14.2.

(vi) At least 90 days before submitting any claim to arbitration, the disputing Investor has transmitted to the Defending Party a written notice of its intention to submit the claim to arbitration ("Notice of Arbitration"). This period of 90 days can run concurrently with the time period provided for in Article 17.3. The Notice of Arbitration shall:

a. attach the Notice of Dispute and the record of its transmission to the Defending Party with the details thereof;

b. provide the consent to arbitration by the disputing Investor, or where applicable, by the locally established Enterprise, in accordance with the procedures set out in this Treaty;

c. provide the waiver as required under Article 17.4 (iii),(iv) and/or (v), as applicable; provided that a waiver from the Enterprise under Article 17.4 (iii),(iv) and/or (v) (as applicable) shall not be required where the Defending Party has deprived the disputing Investor of control of the Enterprise;

d. where consistent with the applicable arbitration centre rules, specify the name of the arbitrator appointed by the disputing Investor.

Article 18. Submission of Claim to Arbitration

18.1 A disputing Investor who meets the conditions precedent provided for in Article 17 may submit the claim to arbitration under:

(a) the ICSID Convention, provided that both the Parties are full members of the Convention;

(b) the Additional Facility Rules of ICSID, provided that either Party, but not both, is a member of the ICSID Convention; or

(c) the UNCITRAL Arbitration Rules.

18.2 The applicable arbitration rules with respect to paragraph 18.1 shall govern the arbitration except to the extent modified by this Chapter, and supplemented by any subsequent rules adopted by the Parties.

18.3 A claim is submitted to arbitration under this Chapter when:

(a) the request for arbitration under paragraph (1) of Article 36 of the ICSID Convention is received by the Secretary-General of ICSID;

(b) the notice of arbitration under Article 2 of Schedule C of the ICSID Additional Facility Rules is received by the Secretary-General of ICSID; or

(c) the notice of arbitration given under the UNCITRAL Arbitration Rules is received by the Defending Party.

18.4 Delivery of notice and other documents on a Party shall be made to the Designated Representative for each Party, as defined in Article 1.2.

Article 19. Consent to Arbitration

19.1 Each Party consents to the submission of a claim to arbitration in accordance with the terms of this Treaty

19.2. The consent given in Article 19.1 and the submission by a disputing Investor of a claim to arbitration shall satisfy the requirement of: (a) Chapter II of the ICSID Convention (Jurisdiction of the Centre) and the Additional Facility Rules for written consent of the parties; and (b) Article II of the New York Convention for an agreement in writing.

Article 20. Appointment of Arbitrators

20.1 The Tribunal shall consist of three arbitrators with relevant expertise or experience in public international law, international trade and international investment law, or the resolution of disputes arising under international trade or international investment agreements. They shall be independent of, and not be affiliated with or take instructions from a disputing party or the government of a Party with regard to trade and investment matters. Arbitrators shall not take instructions from any organisation, government or disputing party with regard to matters related to the dispute.

20.2 One arbitrator shall be appointed by each of the disputing parties and the third arbitrator ("Presiding Arbitrator") shall be appointed by agreement of the co-arbitrators and the disputing parties.

20.3 If a Tribunal has not been constituted within one hundred eighty days (180) days from the date that a claim is submitted to arbitration under this Chapter, the appointing authority under this Article shall be the following:

a. in case of an arbitration submitted under ICSID Convention or the ICSID Additional Facility Rules, the Secretary-General of ICSID;

b. in case of an arbitration submitted under the UNCITRAL Rules, the Secretary-General of the Permanent Court of Arbitration;

provided that if the appointing authority referred to in sub-paragraph (a) or (b) of Article 20.3 is a national of a Party or a state with which, at such time, either Party does not maintain diplomatic relations, the appointing authority shall be in the following order: the President, the Vice-President or the next most senior Judge of the International Court of Justice, in each case who is not a national of either Party or a state with which, at such time, either Party does not maintain diplomatic relations.

20.4 The appointing authority shall appoint in her/his discretion after consultation with the disputing parties, the arbitrator or arbitrators not yet appointed.

Article 21. Prevention of Conflict of Interest of Arbitrators and Challenges

21.1 Every arbitrator appointed to resolve disputes under this Treaty shall during the entire arbitration proceedings be impartial, independent and free of any ac- tual or potential conflict of interest.

21.2 Upon nomination and, if appointed, every arbitrator shall, on an ongoing basis, disclose in writing any circumstances that may, in the eyes of the disputing parties, give rise to doubts as to her/his independence, impartiality, or freedom from conflicts of interest. This includes any relevant circumstances pertaining to the subject matter of the disputes that will create a conflict of interest, and to the existing or past, direct or indirect, financial, personal, business, or professional relationships with any of the parties, legal counsel, representatives, witnesses, or co-arbitrators. Such disclosure shall be made immediately upon the arbitrator acquiring knowledge of such circumstances, and shall be made to the co-arbitrators, the parties to the arbitration and the appointing authority, if any, making an appointment. Neither the ability of those individuals or entities to access this information independently, nor the availability of that information in the public domain, will relieve any arbitrator of his or her affirmative duty to make these disclosures. Doubts regarding whether disclosure is required shall be resolved in favour of such disclosure.

21.3 The arbitrators shall:

a. have experience or expertise in public international law, international investment rules, or in dispute settlement derived from international investment agreements;

b. be independent from the Parties and the disputing Investor, and not be affiliated with or receive instructions from any of them; not take instructions from any organisation or government with regard to matters before the Tribunal for which they are appointed;

c. avoid creating an appearance of bias and not be influenced by self- interest, outside pressure, political considerations, public clamour, loyalty to a Party, disputing party or any other person involved or participating in the proceeding, fear of criticism or financial, business, professional, family or social relationships or responsibilities; not, directly or indirectly, incur any obligation, or accept any benefit, enter into any relationship, or acquire any financial interest that would in any way interfere, or appear to interfere, with the proper performance of their duties, or that is likely to affect their impartial- ity; not use their position as a member of the Tribunal to advance any personal or private interests and avoid actions that may create the impression that others are in a special position to influence them;

d. perform their duties thoroughly and expeditiously throughout the course of the proceeding, and with fairness and diligence;

e. avoid engaging in ex parte contacts concerning the proceeding; and consider only those issues raised in the proceeding and which are necessary for a decision or award and not delegate this duty to any other person.

21.4. The Parties shall by mutual agreement and after completion of their respective procedures adopt a separate code of conduct for arbitrators to be applied in disputes arising out of this Treaty, which may replace or supplement the existing rules in application as amended from time to time. Such a code may address topics such as disclosure obligations, the independence and impartiality of arbitrators and confidentiality.

Article 22. Conduct of Arbitral Proceedings

22.1 Unless the disputing parties agree otherwise, a Tribunal shall hold an arbitration in the territory of a country that is a member of the New York Convention, selected in accordance with: 

(a) the ICSID Additional Facility Rules if the arbitration is under those Rules or the ICSID Convention; or

(b) the UNCITRAL Arbitration Rules if the arbitration is under those Rules.

22.2 Unless otherwise agreed by the disputing parties, the Tribunal may determine a place for meetings and hearings and the legal seat of arbitration. In doing so, the Tribunal shall take into consideration the convenience of the disputing parties and the arbitrators, the location of the subject matter and the proximity of the evidence.

22.3 When considering matters of evidence or production of documents, the Tribunal shall not have any powers to compel production of documents which the Defending Party claims are protected from disclosure under its applicable Law.

Article 23. Dismissal of Frivolous Claims

23.1 Without prejudice to a Tribunal's authority to address other objections, a Tribunal shall address and decide as a preliminary question any objection by the Defending Party that a claim submitted by the Investor is:

(a) not within the scope of the Tribunal's jurisdiction, or

(b) manifestly without legal merit or unfounded as a matter of Law.

23.2 Such objection shall be submitted to the Tribunal as soon as possible after the Tribunal is constituted, and in no event later than the date the Tribunal fixes for the Defending Party to submit its counter-memorial ( or, in the case of an amendment to the Notice of Arbitration, the date the Tribunal fixes for the Defending Party to submit its response to the amendment).

23.3 On receipt of an objection under this Article, the Tribunal shall suspend any proceedings on the merits, establish a schedule for considering the objection consistent with any schedule it has established for considering any other preliminary question and issue a decision or award on the objection, stating the grounds therefor. In deciding an objection under this Article, the Tribunal shall assume to be true claimant's factual allegations in support of any claim in the Notice of Arbitration ( or any amendment thereof). The Tribunal may also consider any relevant facts not in dispute.

23 .4 The Tribunal shall issue an award under this Article no later than 150 days after the date of the receipt of the request under Article 23.2. However, if a Defending Party requests a hearing, the Tribunal may take an additional 30 days to issue the decision or award.

23.5 The Defending Party does not waive any objection as to competence or any argument on the merits merely because the Defending Party did or did not raise an objection or make use of the expedited procedure set out this Article.

23.6 When it decides on a preliminary objection by a Defending Party under this Article 23, the Tribunal may, if warranted, award to the prevailing disputing party reasonable costs and attorneys' fees incurred in submitting or opposing the objection. In determining whether such an award is warranted, the Tribunal shall consider whether either the claim by the disputing Investor or the objection by the Defending Party was frivolous, and shall provide each of the disputing parties a reasonable opportunity to present its case.

Article 24. Transparency In Arbitral Proceedings

24.1 Subject to applicable Law regarding protection of Confidential Information and the mutual written agreement of the disputing parties, the Defending Party shall, to the extent possible, make available to the public the following documents relating to a dispute under this Chapter:

a. the notice of dispute and the notice of arbitration;

b. pleadings and other written submissions on jurisdiction and the merits submitted to the Tribunal, including submissions by a Non-disputing Party;

c. Transcripts of hearings, where available; and

d. decisions, orders and awards issued by the Tribunal.

24.2 Hearings for the presentation of evidence or for oral argument ("hearings") shall, subject to the written consent of the Defending Party, and to the extent possible, be made public in accordance with the following provisions:

a. Where there is a need to protect Confidential Information or protect the safety of participants in the proceedings, the Tribunal shall make arrangements to hold in private that part of the hearing requiring such protection.

b. The Tribunal shall make logistical arrangements to facilitate public access to hearings, including by organizing attendance through video links or such other means as it deems appropriate. However, the Tribunal may, after consultation with the disputing parties, decide to hold all or part of the hearings in private where this becomes necessary for logistical reasons, such as when the circumstances render any original arrangement for public access to a hearing infeasible.

24.3. Subject to the mutual written agreement of the disputing parties, (i) an award of a Tribunal rendered under this Chapter shall be publicly available, subject to the redaction of Confidential Information; and (ii) where a De- fending Party determines that it is in the public interest to do so and notifies the Tribunal of that determination, all other documents submitted to, or issued by, the Tribunal shall also be publicly available, subject to the redaction of Confidential Information.

Article 25. Burden of Proof and Governing Law

25.1 The Disputing Investor at all times bears the burden of establishing: (a) jurisdiction; (b) the existence of an obligation under Chapter II of this Treaty, other than an obligation under Article 10 (Entry and Sojourn of Personnel) or 11 (Transparency); ( c) a breach of such obligation; ( d) that the Investment, or the Investor with respect to its Investment, has suffered actual and non-speculative losses as a result of the breach; and ( e) that those losses were directly caused by the breach.

25.2 The governing law for interpretation of this Treaty by a Tribunal constituted under this Article shall be: (a) this Treaty; (b) the general principles of public international law relating to the interpretation of treaties, including the pre- sumption of consistency between international treaties to which the Parties are party; and (c) for matters relating to domestic law, the law of the Defending Party.

Article 26. Joint Interpretations

26.1 Joint interpretations of specific provisions and decisions on application of this Treaty issued subsequently by the Parties in accordance with this Treaty shall be binding on tribunals established under this Chapter upon issuance of such interpretations or decisions.

26.2 In accordance with the Vienna Convention of the Law of Treaties, 1969 and customary international law, other evidence of the Parties subsequent agreement and practice regarding interpretation or application of this Treaty shall constitute authoritative interpretations of this Treaty and must be taken into account by Tribunals under this Chapter.

Article 27. Award

27.1 An award shall include a judgment as to whether there has been a breach by the Defending Party of any rights conferred under this Treaty in respect of the disputing Investor and its Investment and the legal basis and the reasons for its decisions.

27.2 The Tribunal shall reach its decision by a majority of votes. Such decision shall be final and binding on both disputing parties to the arbitration.

27.3 A Tribunal can only award monetary compensation for a breach of the obligations under Chapter II of the Treaty. Such compensation shall not be greater than an amount determined by such Tribunal with reference to actual loss but monetary damages shall not be greater than the actual loss suffered by the Investor (excluding incidental and consequential damages including future profits, and assets excluded from the scope of this Treaty). Such compensation shall be reduced by any prior damages or compensation already provided by a Party. For the calculation of monetary damages, the Tribunal shall also reduce the damages to take into account any restitution of property or repeal or modification of the measure, or other mitigating factors (6).

27.4 A tribunal may not award punitive or moral damages or any injunctive relief against either of the Parties under any circumstance.

Article 28. Finality and Enforcement of Awards

28.1 An award rendered by a Tribunal shall have no binding force except between the disputing parties and in respect of the particular case.

28.2 Subject to Article 28.3, a disputing party shall abide by and comply with an award rendered by a Tribunal established under this Treaty without delay.

28.3 A disputing party shall not seek enforcement of a final award until:

(a) in the case of a final award made under the ICSID Convention where both the Parties are members of ICSID Convention

(i) 120 days have elapsed from the date the award was rendered and no disputing party has requested revision or annulment of the award; or

(ii) revision or annulment proceedings have been completed; and

(b) in the case of a final award under the ICSID Additional Facility Rules or the UNCITRAL Arbitration Rules

(i) 90 days have elapsed from the date the award was rendered and no disputing party has commenced a proceeding to revise, set aside or annul the award, or

(ii) a court of seat of arbitration has dismissed or allowed an application to revise, set aside or annul the award and there is no further appeal.

28.4 Each Party shall provide for the enforcement of an award in its Territory in accordance with its Law. For the avoidance of doubt, this Article 28.4 shall not prevent the enforcement of an award in accordance with New York Convention.

28.5 A claim that is submitted to arbitration under this Chapter shall be considered to arise out of a commercial relationship or transaction for purposes of Article I of the New York Convention.

Article 29. Costs

The disputing parties shall share the costs of the arbitration, with arbitrator fees, expenses, allowances, and other administrative costs. The disputing parties shall also bear the cost of its own legal representation including experts in the arbitral proceedings.

Article 30. Appeals Facility

Without prejudice to other provisions of this Treaty, the Parties may by mutual agreement establish an institutional mechanism (7) to develop an appellate body or similar mechanism to review awards rendered by Tribunals under this chapter. Such appellate body or similar mechanism may be designed to provide coherence to the interpretation of provisions in this Treaty. In developing such a mechanism, the Parties may take into account the following issues, among others:

a) the nature and composition of an appellate body or similar mechanism;

b) the scope and standard of review of such an appellate body;

c) transparency of proceedings of the appellate body;

d) the effect of decisions by an appellate body or similar mechanism;

e) the relationship of review by an appellate body or similar mechanism to the arbitral rules that may be selected under Articles 22.1 of this Treaty; and

f) the relationship of review by an appellate body or similar mechanism to existing domestic Laws and international law on the enforcement of arbitral awards.