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1. Confidentiality: Terms of confidentiality regarding the dispute and settlement - include if parties want to keep terms private

2. Ongoing Project Completion: Include if there are continuing works to be completed post-settlement

3. Third Party Claims: Provisions dealing with potential third-party claims - include if relevant

4. Tax Implications: Specific provisions about tax responsibilities - include if significant tax considerations exist

5. Dispute Resolution: Process for resolving any disputes about the settlement agreement itself - include if desired

6. Insurance and Indemnities: Specific provisions about ongoing insurance or indemnity obligations - include if relevant

7. Regulatory Compliance: Specific provisions about compliance with regulatory requirements - include if special regulations apply

1. Schedule 1 - Original Contract: Copy or details of the original construction contract

2. Schedule 2 - Dispute Details: Detailed description of all disputes being settled

3. Schedule 3 - Payment Schedule: Detailed breakdown of settlement amounts and payment timeline

4. Schedule 4 - Outstanding Works: List of any remaining works to be completed (if applicable)

5. Schedule 5 - Release Documentation: Forms of release or discharge to be executed

6. Schedule 6 - Project Documents: List of relevant project documents, permits, and certificates

7. Appendix A - Settlement Calculations: Detailed calculations of settlement amounts including any interest or adjustments