I. THE PARTIES’ REQUESTS AND PROPOSALS

1. The Parties seek direction from the Tribunal in relation to the confidentiality regime applicable to the present arbitration. In this respect, each Party has proposed a draft Protocol, which it requests the Tribunal to adopt.

II. PROCEDURAL HISTORY

2. In advance of the First Procedural Meeting, the Tribunal had invited the Parties to consult with each other in relation to the standard of confidentiality that should apply to the present proceedings.

3. By their respective letters dated 27 June 2012 responding to the Tribunal’s invitation, the Respondent informed the Tribunal that it was committed to transparency and did not agree with the Claimant’s proposal that the hearings be held in camera, and the Claimant informed the Tribunal that the Parties disagreed on the standard of confidentiality applicable to the proceedings but that discussions on the matter were ongoing.