In a non-reinsurance matter involving commerce in Turkey, a District Court has vacated an arbitration award due to a failure by the panel chair to disclose that an affiliate of the chair's employer had an ongoing business relationship with the prospective purchaser of a party to the arbitration. This opinion is notable due to the high standard of disclosure imposed by the Court, which was based upon language in the agreement signed by the parties, the American Arbitration Association's Code of Ethics and the International Bar Association's Guidelines on Conflicts of Interest. The panel chair had contended that the total revenue involved in the relationship was an imperceptible fraction of this employer's revenue. Applied Industrial Materials Corp. v. Ovalar Makine Ticaret Ve Sanayi, A.S., Case No. 05-10540 (U.S.N.Y. June 28, 2006).
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