APPENDIX 30

SAMPLE ORDERS FOR SECURITY FOR COSTS

1A. It is ordered that the Claimant gives security for the Respondent’s costs of the claim in the sum of £ / $ / €.

or

1B. It is ordered that the Claimant gives security for the Respondent’s costs of the claim in the sum of £ / $ / € down to the completion of [the memorials] [disclosure and inspection] [witness statements] [expert evidence] with permission to apply for a further sum or sums thereafter.

or

1C. It is ordered that the Claimant gives security for the Respondent’s costs of the claim in the sum of £ / $ / € down to the completion of the memorials; the further sum of £ / $ / € down to the completion of document production; the further sum of £ / $ / € down to the completion of witness statements; the further sum of £ / $ / € down to the completion of expert evidence with permission to apply to both parties to amend such sums.

2. Such security be given by [lodging with the Claimant’s counsel such sum, such sum and all accrued interest to be held by the Claimant’s counsel to the order of the Arbitral Tribunal] [provision of a bank guarantee or a bond in a form and from a bank or insurance company reasonably acceptable to the Respondent] or in such other manner as may be agreed by the parties, by [date] [the following dates respectively].

3. In default of the security being given as directed, all further proceedings be stayed until such security is given.

4. All questions as to the compliance or otherwise with this order (including the form, terms or conditions of any security) be reserved to the Tribunal.