Hill Dickinson trade advantage December 2014

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trade advantage

December 2014

a commodities update

Reforms to the Brussels RegulationThe EU Council Regulation 1215/2012 on jurisdiction and the recognition and enforcement of judgments in civil and commercial matters will come into force on 10 January 2015. This will amend the Brussels Regulation (EU Council Regulation 44/2001) with the aim of streamlining the enforcement of judgments between EU Member States and clarifying the rules for the resolution of jurisdictional disputes.

The new Regulation includes the following major changes:

1. Priority given to the parties’ jurisdiction agreement

Under Article 27 of the current Regulation, where proceedings involving the same cause of action and between the same parties are brought in two Member States, the court second seised must stay its proceedings until the court first seised has ruled on jurisdiction. The practical difficulties of this rule were shown in the West Tankers1 case whereby the ECJ held that an anti-suit injunction could not be granted to prevent proceedings taking place in another Member State, even if those proceedings were contrary to the parties’ jurisdiction agreement. This allowed a claimant to bring a ‘tactical’ claim in a Member State

other than that agreed between the parties in order to delay or curtail the claim.

Article 31(2) of the new Regulation provides that where the parties have made an agreement as to exclusive jurisdiction, if an action is brought in any other Member State the court must stay those proceedings until such time as the court seised pursuant to the jurisdiction agreement has ruled on jurisdiction. This change will remove the risk created by the West Tankers case of a claim being brought in the wrong jurisdiction, so as to delay the progression of the claim. The limit on the application of this new Article is that it is expected it will only apply to agreements as to the exclusive jurisdiction, and not to hybrid jurisdiction agreements.

1. Allianz SpA and Others -v- West Tankers Inc – Case C – 185/07

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WelcomeWelcome to the December edition of Hill Dickinson’s trade advantage newsletter, which we hope you will find of interest.

If you wish to discuss the content of the articles or any other matter connected with the trade, please refer to the list of contacts on page 12 of this newsletter.

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Reforms to the Brussels convention

Seminar on the new Brussels regulation: new year, new law

Ebola virus - the impact on sale contracts

Freezing orders - and the risk of being sent to prison if you breach one

U&M Mining Zambia Ltd -v- Konkola Copper Mines Plc

The “GOLDEN ENDURANCE”

2. Preservation of the arbitration exception

The West Tankers case also found that ’a preliminary issue concerning the applicability of an arbitration agreement, including in particular its validity, also comes within its [Regulation 44/2001] scope of application’. This has had the effect, as discussed above, of drastically reducing the power of an English arbitration tribunal until the jurisdiction has been ruled on by the court first seised.

The new Regulation has stepped in to ameliorate this situation by preserving the old position in Article 2(d) that the Regulation does not apply to arbitration proceedings. The arbitration exemption has been enhanced by Article 73(2) which provides that the ’Regulation shall not affect the application of the 1958 New York Convention’.

Recital 12 of the new Regulation also provides helpful guidance as to what exactly will fall within the scope of the Regulation with regard to arbitration proceedings. It provides that the court of a Member State when seised of an action in a matter in respect of which the parties have entered into an arbitration agreement may refer the parties to arbitration, stay or dismiss the proceedings or examine whether the arbitration agreement is null and void, inoperative or incapable of being performed.

3. Judgments will be automatically enforceable across EU Member states

Article 38 of the current Regulation provides that a judgment must be declared enforceable in the Member State in which it is being enforced, following an application governed by the law of the Member State in which enforcement is sought.

Article 39 of the new Regulation abolishes this rule by providing that ’a judgment given in a Member State which is enforceable in that

Member State shall be enforceable in the other Member States without any declaration of enforceability being required’.

This is a dramatic and hugely beneficial change which will reduce costs and delay and improve the ease with which judgments can be enforced between Member States. There are of course safeguards to this new Article found in Article 45 and 46, for instance recognition of a judgment shall be refused if it is ’manifestly contrary to public policy‘ or ’where the judgment was given in default of appearance, if the defendant was not served with the document…’.

4. Jurisdiction agreements are treated as separable from the substantive contract

Article 25(5) of the new Regulation provides that a jurisdiction agreement is to be treated as independent of the other terms of the contract. This broadly reflects the current English law position. The practical effect of this means that the validity of the jurisdiction agreement cannot be challenged solely on the basis that the contract is invalid.

Conclusion

The new Regulation is long overdue and appears to be commercially and practically beneficial, particularly in terms of reducing the negative impact created by the West Tankers decision. It remains to be seen in practice what improvements the new Regulation will have on the speed and ease with which judgments can be arrived at and then enforced within the EU. However, in principal, costs and delay should be drastically reduced.

Sophie Compton [email protected]

Edward Hicks [email protected]

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a commodities update December 2014

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If you would like to hear more on this topic, we are holding a seminar on 8 January 2015 that will be chaired by Professor Sir Francis Jacobs, KCMG, QC, former Advocate General at the Court of Justice of the European Communities.

Other speakers are Hill Dickinson’s Philip Wareham, Jeremy Robinson and Robert Gay. Please contact Claire Messer for further details: [email protected].

Seminar on the new Brussels Regulation - new year, new law: what will the new Brussels Regulation mean for you?

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Ebola virus – the impact on sale contractsThe Ebola Virus (EVD) is a deadly disease and the current outbreak has seen over 14,000 reported cases and 5000 deaths in seven countries, principally in Sierra Leone, Guinea and Liberia. In our previous article – ‘Ebola Virus – The Legal Challenges’ - we discussed some of the relevant legal considerations from a shipping perspective. We showed how the EVD outbreak could affect the respective duties of parties trading on CIF and FOB terms, issues around the nomination and re-nomination of vessels, the substitution of vessels and ports, and potential exposure to quality disputes from cargo interests.

This article focuses specifically on sale contracts and the criteria under which force majeure and frustration might be invoked. The three worst

affected countries are significant grain importers. Guinea is a major exporter of bauxite, the aluminium ore. There are growing fears that EVD could reach the Ivory Coast which produces two thirds of the world’s cocoa beans. Imported commodities such as rice and palm oil have already seen prices rise sharply due to perceived scarcity.

EVD is likely to cause delays and disruptions which may not be specifically covered by the sale contract. The question is who bears the risk of those disruptions and the associated costs?

Legal considerations (1) Force majeure

A force majeure clause is generally invoked when parties cannot fulfil their contractual obligations because of unforeseen and catastrophic circumstances.

Instances of force majeure may include:

- a port authority has closed its ports to foreign vessels because of a spread of infection;

- a port has refused entry to vessels which have loaded at West African ports; or

- a Master has refused to enter an open port because of their fears of contagion.

However, each force majeure clause is unique to the particular contract in question. Parties will therefore need to assess carefully whether a declaration of force majeure by them or their counterparty is valid under the terms of their contract. Such clauses need to be read strictly as to what the parties intended at the time the contract was concluded. If issues of public health are not specifically mentioned, a party may nonetheless seek to rely on a catch all exception such as ‘any other event…’. Whether they can will depend on the clause as a whole. Broadly drafted clauses, such as those adding the word ‘whatsoever’, can give the clause a wider reading.

If the event does fall within the scope of the clause, a party may not be entitled to declare force majeure immediately. They should follow the procedural requirements of the clause. For example:

- the clause may require the shipment period to expire before it can be invoked;

- the event relied on may have had to be in existence for a certain period of time; and

- there may be strict notice requirements to observe.

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Parties trading on GAFTA terms will face additional uncertainty since the new ‘Prevention of Delivery’ clause does not automatically lead to cancellation but first provides for a temporary suspension of the contract. Where this or similar clauses are incorporated, it is important that parties do not make a premature declaration of force majeure. This could constitute an anticipatory breach of the contract, which carries the risk of oneself being held in default.

In addition to showing that their force majeure clause covers the effects of EVD, a party seeking to rely on an appropriately drafted clause will need to show that they are physically or legally prevented from shipping the goods. The virus must be beyond the parties’ control – they cannot have themselves contributed to the event. Parties will need to provide evidence of the impossibility of performing the contract. At the very least this will include showing the steps taken to try and prevent or avoid the impact of EVD. WHO have issued a number of circulars informing parties of preventative measures, including a blueprint to be followed. Failure to adhere to those standards could be fatal to a claim of force majeure.

For a party disputing that force majeure applies, there may be scope to argue that EVD was foreseeable at the time the contract was entered into and is not covered by the clause. There is no general principle in English law to this effect, and much will depend on the construction of the force majeure clause and when the contract was made. If the contract was agreed before the widespread outbreak of Ebola in the area or country of performance, then there may be a valid force majeure argument. If the contract was concluded after the problem was generally known, and particularly if the contract was to be performed in one of the affected countries, it could be implied that the parties agreed to performance notwithstanding the outbreak.

The consequence of invoking a force majeure clause will largely depend on the clause in question. Increasingly, commodity sale contracts permit an extension of time in which to perform, rather than relieving the invoking party of their obligations. When agreeing to such a clause, it would be prudent for a buyer to consider terms which modify the contractual price payable or give over monetary relief where EVD causes a delay to performance.

(2) Frustration For contracts incorporating English law and jurisdiction the doctrine of frustration may apply. If an unforeseen event, caused by neither party, occurs after the formation of the contract, which renders it physically impossible or illegal to fulfil the contract, or transforms the obligation to perform into a radically different one, then frustration may operate to discharge the parties from their further obligations.

For example, if the discharge port in a CIF contract has imposed an absolute ban on cargoes coming from West African ports, the seller cannot perform. There will be scope for them to argue that the contract has been frustrated by supervening illegality.

If EVD was widely acknowledged as a problem at the time the contract was entered into, it is arguable that the party seeking to rely on frustration should have taken precautionary measures to ensure they could perform. This might include shipping from an alternative port, or shipping goods of a different origin. This may then be an insuperable barrier to a defence of frustration. A party seeking to rely on frustration will therefore need to demonstrate that there are no alternative means of performing the contract in accordance with its terms.

The legal effect of a valid frustration claim will largely depend on the terms of the parties’ respective contracts and the facts of the case. However, it is always important to note that, under English law, sums that have already fallen due before the frustrating event will generally remain payable.

Conclusion Traders should keep up with the evolving situation, identify the commodities which are most likely to be affected, and pay close attention to their contractual arrangements. Much depends on the construction of individual clauses. When faced with a potential force majeure or frustration situation, it is of key importance to gather evidence that demonstrates that the event was unforeseeable, and to explore alternative (contractual) means of performance. Failure to do so could be fatal.

The narrow application of force majeure clauses means that parties would be best advised to draft specific detailed clauses which address: a) what diseases are covered by the clause, and b) the degree of seriousness required before force majeure can be invoked. For contracts which are already in place, parties should consider whether specific addenda can be agreed.

a. A clause which specifically addresses EVD reduces the potential for a dispute as to its application to the disease. However, new related diseases which are later identified may still not be covered by such a clause.

b. Parties should consider the degree of seriousness required for the force majeure clause to bite. They should set specific criteria which can be measured objectively, for example the trigger could be that the disease is the subject of a WHO declared public health emergency of international concern (PHEIC).

However, parties should ensure that if they do incorporate bespoke clauses into their contracts, these are on back-to-back terms with their supply and on-sale contracts so as to limit exposure. They should also seek to incorporate specific clauses into their charterparties, where possible.

Edward Hicks [email protected]

Jasmin Sandhu [email protected]

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Freezing orders - and the risk of being sent to prison if you breach one Freezing orders are a familiar means of preventing a defendant from disposing of its assets prior to judgment. But, for the directors and officers of any company subject to a freezing order, they also represent the risk of criminal proceedings for contempt of court if breached.

Two recent cases review the risks to directors or officers of breaching a freezing order and offer some useful guidance on how the courts approach the issue.

What constitutes contempt of court?

In the recent cases of IPartner Pte Shipping Ltd -v- Panacore Resources DMCC1 and Public Joint Stock Company Vseukrainskyi Aktsionernyi Bank -v- Sergey Maksimov & Others2, the Commercial Court set out the ingredients of contempt of court in the context of freezing orders:

1. The order must contain a penal notice i.e. a warning that failure to comply with the order may result in criminal sanctions.

2. A person subject to the order must either have failed to do, within the time allowed, something which the order required him to do, or done something which he was specifically forbidden from doing.

3. The contempt must be proved beyond all reasonable doubt – i.e. to the criminal standard of proof.

4. It must be shown that each party charged with contempt knew of the terms of the order, that they acted in such a way as to breach the order, and that they knew of the facts which made that conduct a breach.

5. It is contempt if an intentional act amounts to a breach of the order – even if it cannot be shown that the relevant party knew or believed that the intentional act would amount to a breach.

6. Where a company is ordered not to do certain acts, and a director of that company is aware of the order, he is under a duty to take reasonable steps to ensure that the order is obeyed. If he wilfully fails to take those steps and the order is breached, he can be punished for contempt (the position may be different if the director reasonably believes some other director or officer is taking those steps).

Guidance from the court

Contempt of court carries serious criminal penalties, which can include a fine, seizure of the director’s personal assets – or up to two years’ imprisonment. That said, an order for committal contempt remains in the discretion of the court, and the recent cases provide useful guidance as to how the court will exercise that discretion, as follows:

• Where a freezing order requires that a company does something to, for example, the ’best of [its] ability‘, that necessarily means looking at the conduct of the people through whom the company acts e.g. its directors or officers. A committal order can be made against any director or officer of a company provided the injunction was served on them personally.

• An order requiring a party to do something to the ‘best of [its] ability’ will not generally be interpreted as an absolute obligation. Failure to perform an impossible task is not, of itself, contempt - although it may still amount to a breach of the order.

• If a party fears that he might be unable to comply with the terms of an order, he must apply to vary the terms as soon as possible – it will not generally be a defence to say later that he ran out of time.

• Given the very serious consequences of breaching a freezing order, any ambiguity in the order will be resolved in favour of the party alleged to be in breach.

Comment

Directors and officers of companies subject to a freezing order must be careful to ensure compliance with the terms of the order - or they personally could face a conviction for contempt of court. Allegations of contempt must be proved beyond reasonable doubt, and any ambiguity will be resolved in favour of the defendant. Nevertheless, if it becomes clear that an order cannot be complied with, it is vital that the affected parties make an application to vary or discharge the order without delay.

Sophie Compton [email protected]

Gordon Campbell [email protected]

1 [2014] EWHC 36082 [2014] EWHC 3771

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U&M Mining Zambia Ltd -v- Konkola Copper Mines Plc [2014] The Commercial Court considered an application to continue a worldwide freezing order (WFO) in support of an award in an arbitration seated in England and Wales and reviewed the applying party’s duty of ‘full and frank’ disclosure.

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This is the latest judgment to emerge from the ongoing dispute between U&M Mining Zambia Ltd (U&M) and Konkola Copper Mines Plc (KCM). In June 2014, U&M applied for – and was granted - a WFO in support of sums awarded by a tribunal in a London arbitration. U&M then applied to continue the WFO.

The court granted the continuation. In doing so, it looked at KCM’s conduct during the arbitration: in particular, KCM’s reliance - on two occasions - upon untrue evidence, and its apparent willingness to cause unnecessary harm to U&M. None of that conduct amounted, in itself, to a breach of the existing WFO. Nevertheless, the court held that an entity whose employees are willing to give untrue evidence, cause unnecessary harm, obstruct the arbitration process and take untenable points with a view to delaying enforcement might well also seek to deal with its assets other than in the ordinary course of business with a view to making enforcement of arbitration awards more difficult.

The court noted that the majority of KCM’s assets were located in Zambia, that enforcement would take place in Zambia, and that the Zambian court also had the power to grant WFOs. Nevertheless, where the seat of arbitration is in England, it will ordinarily (and subject always to the court’s discretion) be appropriate for the English court to make orders, such as WFOs, in support of the arbitration. The mere fact that enforcement of an award will take place overseas was not, by itself, sufficient to make it inappropriate for the English court to grant a WFO.

This case also provides useful guidance on the applicant’s duty to give ’full and frank’ disclosure when seeking a WFO. Applications for WFOs are typically made without notice to the affected party and the applicant is accordingly under a duty to show utmost good faith, to disclose his case fully and fairly, to identify the crucial points for and against the application, and to disclose all facts which the court might reasonably take into account. Failure to

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give this ’full and frank‘ disclosure can result in the WFO being discharged - even if the court later finds that the order would properly have been granted had full disclosure been made.

In this case, the court found that U&M had committed ’serious and numerous‘ breaches of its duty to give full and frank disclosure – but that it was, nevertheless, just and convenient to continue the WFO. In coming to this decision, the court noted that:

• UCM’s failure to comply with its duty of full and frank disclosure related to matters involving the finances of KCM. It did not relate to the conduct of KCM in the arbitration or subsequently, and it was that conduct from which the court inferred the risk that KCM would – if not restrained by a WFO - seek to deal with its assets so as to make enforcement of the awards more difficult.

• The failures to comply were ’innocent‘ in the sense that they were not deliberate. The material submitted by UCM with its original application indicated an intention to put all matters thought to be relevant before the court. The court was satisfied, on the facts, that UCM’s failure to put certain matters before the court may have arisen from a failure to appreciate the relevance of those matters.

• The court must emphasise the importance of complying with the duty of full and frank disclosure, and ensure applicants discharge that duty. It was not, however, necessary to discharge the WFO to meet that purpose: it could be satisfactorily achieved, in an appropriate case, by an order as to costs.

Comment

This case confirms the English court’s readiness to look at the parties’ conduct in deciding whether to grant or continue a WFO, and to issue WFOs even where the assets are located outside of the jurisdiction. The case also indicates that an innocent failure to give full and frank disclosure may not be fatal to an application to continue a WFO, and that the courts accordingly recognise the balance between the applicant’s duty to give full and frank disclosure, and the harm they might suffer if a WFO were to be prematurely discharged.

Alexandra Chandran [email protected]

Gordon Campbell [email protected]

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The “GOLDEN ENDURANCE”Golden Endurance Shipping SA -v- RMA Watanya SA & Ors [2014] The Commercial Court recently considered an application by cargo receivers and their insurers to set aside an order for service out of the jurisdiction in respect of proceedings brought against them by shipowners. Although the case principally concerned jurisdictional issues, we focus here on how the court reconciled the use of conflicting editions of the Congenbill form for the Bill of Lading, and its approach to the absence of a signed charterparty.

BackgroundDispute had arisen regarding damage to cargo carried on the “GOLDEN ENDURANCE” from three African ports to Morocco, pursuant to three separate bills of lading.

The cargo receivers and their subrogated insurers (Cargo Interests) arrested the vessel in Casablanca. Cargo Interests also issued substantive proceedings relating to the cargo damage before the Casablanca court.

Shipowners were apparently unhappy with delays regarding security (and presumably the release of their vessel) and applied to the English court for an anti-suit injunction against the Moroccan proceedings. Various other steps were taken, but of particular note for these purposes is the fact that shipowners obtained leave to serve out their English proceedings on Cargo Interests and the latter sought to challenge that order.

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Issues before the English court in relation to the Lomé Bill of LadingCongenbill 1978 -v- 1994: an obvious muddle

The front page of the Lomé Bill was on the Congenbill 1978 form. However, its reverse was on the 1994 form. No explanation was given, although as the court noted, there was ‘obviously a muddle’.

The parties were in disagreement as to which of the standard Congenbill terms applied. It suited shipowners to rely on the provisions set out on the reverse (the 1994 version), while Cargo Interests preferred to rely on the 1978 edition, arguing that those terms applied given the use of the Congenbill 1978 front page.

The difference was important in terms of the applicable law and jurisdiction clause and the applicable cargo convention.

Most notably, it will be appreciated that the earlier 1978 Congenbill form does not include specific reference to a charterparty’s law and arbitration clause. This was a revision made to the 1994 standard form which reads:

‘All terms and conditions, liberties and exceptions of the Charter-Party, dated as overleaf, including the Law and Arbitration Clause, are herewith incorporated.’

In effect, if the 1978 standard terms applied, there was no reference to the charterparty’s law and arbitration clause and Cargo Interests would look to the Hamburg Rules and the Moroccan Court. If the 1994 terms applied, the Bill of Lading did incorporate the ‘Law and Arbitration Clause’ of the charterparty and, in this case, the dispute should be dealt with under English law, and by reference to the Hague Rules.

Cargo Interests relied on the House of Lords decision in “THE STARSIN” in support of their interpretation that the front page of the Bill of Lading was the key focus. In “THE STARSIN” there was an inconsistency between the description of the carrier on the front page of the Bill of Lading and in the terms on the reverse. Cargo Interests referred in particular to Lord Steyn’s judgment, which stated:

‘…In my view he [i.e. the reasonable man experienced in shipping matters] would give greater weight to words specially chosen, such as the words which appear above the signature, rather than standard form printed conditions. Moreover, I have no doubt that in any event he would, as between provisions on the face of the bill and those on the reverse side of the bill, give predominant effect to those on the face of the bill.’

The court was not persuaded. It did not consider that “THE STARSIN” decision was conclusive of an analysis that the terms on the front would always be preferred over the terms on the reverse. Each case must be decided on its individual facts. Here, the conditions of carriage were clearly and legibly set out on the reverse of the Lomé Bill. There was no need, for example, to cross refer to the Congenbill 1994 terms: they were printed on the Lomé Bill. Construing the document in a business sense, it was logical to accept the incorporation of conditions which had been specifically set out in the Bill of Lading, as opposed to those said to be incorporated on its face.

As a result, the 1994 terms were found to apply.

The applicable charterparty

However, matters did not rest there. Not unusually, there was no signed charterparty. Cargo Interests argued that there was therefore no effective law and arbitration clause. In particular, they submitted:

(i) the fixture recap (and/or letter/enclosures) was ‘uncertain and incomplete’;

(ii) the relevant charterparty was the head charter, and there was either no head charter or no written head charter; and/or

(iii) there was no evidence of a written charterparty before the goods were discharged.

The court was not persuaded by any of these points. It accepted the ‘powerful’ arguments made by shipowners:

(i) Shipowners relied upon an internal email from the agents as the fixing recap. It left some matters incomplete, including the owners’ bank details, the identity of underwriters and the estimated maximum cargo quantity. It attached

a standard form charterparty and the covering email stated ‘fixture (if any) is concluded with disp owners’. The court agreed that none of the incomplete details were significant to indicate that there was no consensus as to the existence of a contract. The court further noted the fact that the email annexed a standard form charterparty, and that a subsequent charterparty (albeit unsigned) included all relevant terms;

(ii) For an English law clause to be incorporated, the charterparty had to be evidenced in writing. It plainly was so, as noted above.

There was no debate either that if two or more relevant charters existed, one generally presumed that the head charter applied. But this was of no assistance to Cargo Interests here. It did not matter that there was no separate written charterparty as between head owners and disponent owners: the court noted that they were related (common ownership and control), and both names appeared in the fixture recap and the (unsigned) charterparty. It was therefore clear to the court that there was only one charterparty (to which both head owners and disponent owners were a party), and this was obviously the relevant charterparty; and

(iii) As per the “EPSILON ROSA”, the lack of an executed (signed) charterparty prior to discharge of the cargo is not fatal to a case that the charterparty is incorporated into the Bill of Lading. The decisive factor was that the terms were agreed before discharge. The court accepted the evidence of the fixture recap and attached standard terms as being the terms applicable to this Bill of Lading. It was that charterparty’s law and arbitration clause that would be incorporated.

Claire Messer [email protected]

Jasmin Sandhu [email protected]


London Piraeus Singapore Monaco Hong Kong Liverpool Manchester Sheffield

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For further details please contact:

Claire Messer Senior Associate +44 (0)20 7280 9129 [email protected]

The information and any commentary contained in this newsletter are for general purposes only and do not constitute legal or any other type of professional advice. We do not accept and, to the extent permitted by law, exclude liability to any person for any loss which may arise from relying upon or otherwise using the information contained in this newsletter. Whilst every effort has been made when producing this newsletter, no liability is accepted for any error or omission. If you have a particular query or issue, we would strongly advise you to contact a member of the commodities team, who will be happy to provide specific advice, rather than relying on the information or comments in this newsletter.

About Hill DickinsonThe Hill Dickinson Group offers a comprehensive range of legal services from offices in London, Piraeus, Singapore, Monaco, Hong Kong, Liverpool, Manchester and Sheffield. Collectively the firms have more than 1300 people including 180 partners.

London office

Singapore office

Andrew Lee Partner +65 6576 4722 [email protected]

Stuart Armstrong Partner +44 (0)20 7280 9121 [email protected]

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Jeff Isaacs Head of Commodities +44 (0)20 7280 9125 [email protected]

Fred Konynenburg Partner +44 (0)20 7280 9250 [email protected]

Susan Leonard Legal Director +44 (0)20 7280 9275 [email protected]

Gordon Campbell Senior Associate +44 (0)20 7280 9179 [email protected]

Claire Messer Senior Associate +44 (0)20 7280 9129 [email protected]

Edward Hicks Senior Associate +44 (0)20 7280 9132 [email protected]

Avnish Shah Associate +44 (0)20 7280 9140 [email protected]

Jasmin Sandhu Paralegal +44 (0)20 7280 9128 [email protected]

Lawrence Lagnado Senior Associate +44 (0)20 7280 9161 [email protected]

David Lucas Partner +44 (0)20 7280 9208 [email protected]

Kamal Mukhi Legal Director +44 (0)20 7280 9258 [email protected]

Paul Taylor Partner +44 (0)20 7280 9261 [email protected]

Darren Wall Partner +44 (0)20 7280 9265 [email protected]

Shanna Ghose Legal Director +65 6576 4726 [email protected]

Hill Dickinson trade advantage December 2014

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