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1. Parties: Identifies and provides full details of all parties to the agreement
2. Background: Sets out the context of the dispute or circumstances leading to the settlement
3. Definitions and Interpretation: Defines key terms and establishes interpretation principles
4. Settlement Sum: Specifies the amount to be paid and payment terms
5. Tax Treatment: Addresses taxation implications and responsibilities
6. Release and Bar to Future Claims: Mutual releases from claims and prevents future actions
7. Confidentiality: Obligations regarding confidentiality of the settlement and its terms
8. Non-disparagement: Mutual obligations not to make adverse comments about other parties
9. Legal Advice: Acknowledgment of independent legal advice or opportunity to seek it
10. Entire Agreement: Confirms the agreement represents the complete understanding between parties
11. Governing Law: Specifies applicable law and jurisdiction
12. Execution: Signing provisions and execution requirements
1. Ongoing Employment Terms: Required if the employee is continuing employment with modified terms
2. Return of Property: Include when there is company property to be returned
3. Intellectual Property: Required if there are IP rights to be assigned or protected
4. Reference and Future Employment: Include if terms about references or future employment are agreed
5. Restraint of Trade: Include if post-settlement competitive restrictions apply
6. Payment Schedule: Required if settlement involves multiple installment payments
7. Deed of Release: May be separate if additional formality is required
8. Superannuation: Include if settlement includes superannuation components
9. Existing Proceedings: Required if there are ongoing legal proceedings to be discontinued
1. Schedule 1 - Payment Details: Detailed breakdown of settlement sum components
2. Schedule 2 - Claims Released: Comprehensive list of claims being settled and released
3. Schedule 3 - Return of Property Schedule: Itemized list of property to be returned
4. Schedule 4 - Agreed Announcement: Any agreed internal or external communications regarding the settlement
5. Appendix A - Deed of Release: Form of release if provided as separate document
6. Appendix B - Tax Declaration: Required tax forms or declarations
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Executive Leadership
Risk and Compliance
Industrial Relations
Employee Relations
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