... of the agreement does therefore not include the arbitration clause. Hence, if the parties have not agreed on the applicable law governing the validity and scope of the arbitration clause, this will be determined to be the law of the country where the arbitration proceedings are to be held.3 The law governing the proceedings is, unless otherwise agreed upon by the parties, the law of the country in which the proceedings are held.4 For the purposes of this article, up to three legal systems may have to be taken into consideration when reviewing the effects of the Judgment. 2.2 The previous legal position in Sweden Under the Swedish Arbitration Act5 (in effect April 1, 1999) there are no rules with regard to confidentiality for parties and arbitrators involved in the proceedings. Neither was the issue of confidentiality addressed in the earlier arbitration act of 1929, applicable to the Judgment. However, as confidentiality ...

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