This settlement agreement is made on [insert date] (the ‘Settlement Date’) between the following parties (each a ‘party’ and together the ‘parties’):

Parties

1. 1

   [insert name of party A] a company incorporated in [England and Wales] whose company number is [insert company number] and whose registered office is at [insert registered office] ('[Name of party A]'); and

1. 2

   [insert name of party B] a company incorporated in [England and Wales] whose company number is [insert company number] and whose registered office is at [insert registered office] ('[Name of party B]').

Background

1. 1. (A)

      The parties entered into a construction contract dated [insert date] for the [insert description of works/project, eg ‘design and construction of a property known as Bloggs House'] (the ‘Contract’).

   1. (B)

      [The parties are engaged in a dispute[ regarding [insert details of the dispute, including material facts, potential causes of action and alleged losses—for guidance on issues to consider see the drafting notes] OR , full details of which are set out in the schedule attached] (the ‘Dispute’).

      OR

      The parties are engaged in proceedings in