APPENDIX 4

SAMPLE ANSWER TO REQUEST

IN THE MATTER OF AN ARBITRATION UNDER THE RULES OF THE INTERNATIONAL CHAMBER OF COMMERCE

BETWEEN:

A

Claimant

v.

B

Respondent

ANSWER TO REQUEST FOR ARBITRATION

A. Introduction

1. In this Answer B sets out its defence to the claims advanced by A in the Request and sets-off and counterclaims as appearing below.

2. The purpose of this Answer is to comply with Article 5 of the ICC Rules and set out a general summary of the matters in dispute. For the avoidance of doubt B reserves the right to raise any and all further claims arising out of or in connection with the disputed matters described in this Answer or otherwise arising between the parties under the Agreement as defined in the Request. Further B reserves the right to produce such further documents, evidence of fact, expert opinion or legal arguments as may be necessary to present its case or rebut any case that may be put forward by the Claimant.