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1. Parties: Identification of the employer and employee with full legal names and addresses
2. Background: Brief history of employment relationship, existence of dispute/claims, and parties' desire to settle
3. Definitions: Definitions of key terms used throughout the agreement
4. Settlement Terms: Core settlement amount and payment terms
5. Tax Implications: Treatment of settlement payment for tax purposes and responsibilities of each party
6. Mutual Release and Waiver: Comprehensive release of claims by both parties
7. Confidentiality: Obligations to keep settlement terms and discussions confidential
8. Return of Company Property: Requirements for returning company assets, documents, and data
9. Non-Disparagement: Mutual obligations not to make negative statements about each other
10. References: Agreement on the format and content of future employment references
11. Governing Law: Specification of Pakistani law as governing law and jurisdiction
12. Entire Agreement: Confirmation that this document represents the complete agreement between parties
13. Execution: Signature blocks and execution requirements
1. Post-Employment Restrictions: Include when new or modified non-compete or non-solicitation terms are part of settlement
2. Benefits Continuation: Include when settlement includes ongoing benefits or insurance coverage
3. Legal Costs: Include when addressing payment of legal fees and costs
4. Equity/Share Treatment: Include when employee holds company shares or stock options
5. Cooperation in Pending Matters: Include when employee's assistance may be needed in ongoing business matters
6. Immigration Status: Include when settlement affects work visa or immigration status
7. Re-Employment: Include when addressing possibility of future employment with company
8. Severance Benefits: Include when settlement includes additional severance package terms
1. Schedule A - Settlement Payment Breakdown: Detailed breakdown of settlement amount components
2. Schedule B - Company Property List: Itemized list of company property to be returned
3. Schedule C - Reference Letter: Agreed form of reference letter
4. Schedule D - Claims Being Settled: Comprehensive list of claims being settled and released
5. Schedule E - Resignation Letter: Agreed form of resignation letter if applicable
6. Schedule F - Continuing Obligations: List of any surviving obligations from employment contract
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