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1. Parties: Identifies and defines all parties to the settlement agreement, including their legal status and addresses
2. Background: Outlines the context of the dispute and the parties' desire to settle all claims
3. Definitions and Interpretation: Defines key terms used throughout the agreement and establishes interpretation rules
4. Settlement Sum: Specifies the settlement amount, payment terms, and payment method
5. Settlement Terms: Details the core obligations and actions required from each party to effect the settlement
6. Release and Waiver: Mutual releases of claims and waiver of rights related to the disputed matter
7. Confidentiality: Obligations regarding non-disclosure of the settlement terms and related information
8. Tax Implications: Addresses responsibility for any tax consequences arising from the settlement
9. Entire Agreement: Confirms the agreement represents the complete understanding between parties
10. Governing Law and Jurisdiction: Specifies Hong Kong law as governing law and jurisdiction for disputes
11. Execution: Signature blocks and execution requirements
1. Non-Admission of Liability: Statement that the settlement does not constitute admission of liability by any party - used when specifically requested by settling parties
2. Non-Disparagement: Mutual obligations not to make negative statements about other parties - important in high-profile or sensitive disputes
3. Return of Documents: Requirements for returning or destroying confidential documents - relevant when sensitive materials were exchanged
4. Future Cooperation: Obligations for parties to cooperate on related matters - useful in ongoing business relationships
5. Insurance and Indemnity: Provisions related to insurance claims and indemnification - relevant when insurance is involved in the settlement
6. Publicity and Announcements: Rules for making public statements about the settlement - important for high-profile cases
7. Surviving Obligations: Identifies which obligations continue after settlement completion - used when certain obligations should persist
1. Schedule 1 - Payment Schedule: Detailed breakdown of payment installments, dates, and methods if payment is not made as a lump sum
2. Schedule 2 - Released Claims: Comprehensive list of all claims being settled and released
3. Schedule 3 - Settlement Sum Allocation: Breakdown of how settlement sum is allocated among different claims or parties if applicable
4. Schedule 4 - Required Actions: Detailed list of specific actions required by each party to implement the settlement
5. Appendix A - Related Proceedings: List of all legal proceedings to be discontinued as part of the settlement
6. Appendix B - Form of Release: Template for any additional release documents required to be executed
Interpretation
Settlement Payments
Payment Terms
Settlement Obligations
Release of Claims
Confidentiality
Non-Admission of Liability
Non-Disparagement
Tax Matters
Warranties and Representations
Further Assurance
Costs
Assignment
Severability
Variation
Waiver
Notices
Third Party Rights
Execution
Counterparts
Governing Law
Jurisdiction
Entire Agreement
Financial Services
Professional Services
Real Estate
Construction
Manufacturing
Technology
Retail
Healthcare
Education
Insurance
Telecommunications
Transportation and Logistics
Energy and Utilities
Media and Entertainment
Legal
Compliance
Risk Management
Executive Leadership
Finance
Human Resources
Corporate Secretariat
Operations
Business Development
Contract Administration
Legal Counsel
Chief Legal Officer
Compliance Officer
Risk Manager
Chief Executive Officer
Chief Financial Officer
Corporate Secretary
Managing Director
Head of Legal
Dispute Resolution Manager
Settlement Officer
Claims Manager
Human Resources Director
Business Unit Manager
Contract Manager
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